①The provisions of Article 57, paragraph (9) and Article 58, paragraph (4) of the New Corporation Tax Act apply to the net operating loss in the business year that includes the day before the date of a company split by split-off or merger in the case where a corporation carries out, on or after the Effective Date, the company split by split-off or merger in which the corporation is the splitting corporation or acquired corporation, and with regard to the net operating loss in the business year that includes the day before the date of a company split by split-off or merger in the case where a corporation carried out, before the Effective Date, the company split by split-off or merger in which the corporation was the splitting corporation or acquired corporation, the provisions then in force continue to govern.

②In the case where a subsidiary corporation under the transitional measures or a corporation joining during the transitional period (referred to as a "subsidiary corporation, etc. under the transitional measures" in this paragraph and Article 13, paragraph (2) of the Supplementary Provisions) has carried out, in the business year subject to the transitional measures (or, for the business year subject to the transitional measures that includes the Effective Date, in the period from the Effective Date to the last day of that business year subject to the transitional measures), a company split by split-off in which the subsidiary corporation, etc. under the transitional measures is the splitting corporation, for the purpose of applying the provisions of Article 57, paragraph (9), item (i) of the New Corporation Tax Act in the business year of the subsidiary corporation, etc. under the transitional measures that includes the day before the date of the company split by split-off, the phrase "consolidated parent corporation business year" in (a) of that item is deemed to be replaced with "first consolidated business year".