①The provisions of Article 62, paragraph (1), Article 62-2, paragraph (3) and Article 62-6, paragraph (1) of the New Corporation Tax Act apply to company splits carried out by a corporation on or after the Companies Act Effective Date, and with regard to company splits carried out by a corporation before the Companies Act Effective Date, the provisions then in force continue to govern.

②With regard to the application of the provisions of Article 62-2 of the New Corporation Tax Act in the case where a corporation carried out a qualified company split by split-off during the period from the Effective Date to the day preceding the Companies Act Effective Date, the phrase "the preceding paragraph (limited to the part pertaining to a qualified merger)" in paragraph (2) of that Article is deemed to be replaced with "the preceding paragraph", the phrase "acquiring corporation" is deemed to be replaced with "acquiring corporation or succeeding corporation in a company split", the phrase "Article 61-2, paragraph (3)" is deemed to be replaced with "Article 61-2, paragraph (4)", and the phrase "the qualified merger" is deemed to be replaced with "the qualified merger or Qualified Company Split by Split-Off referred to in the preceding paragraph".

The provisions of Article 62-8 of the New Corporation Tax Act apply to a non-qualified merger, etc. prescribed in paragraph (1) of that Article that a corporation carries out on or after the Companies Act Effective Date.

The provisions of Article 62-9 of the New Corporation Tax Act apply to share exchanges and share transfers carried out by a corporation on or after October 1, 2006.

The provisions of Article 63, paragraph (3) of the New Corporation Tax Act apply to corporation tax on income for business years of a corporation ending on or after October 1, 2006.

The provisions of Article 66, paragraphs (1) through (3) of the New Corporation Tax Act apply to corporation tax on income for business years of a corporation commencing on or after January 1, 2007, and with regard to corporation tax on income for business years of a corporation that commenced before that date, the provisions then in force continue to govern.

①The provisions of Article 67, paragraph (4) of the New Corporation Tax Act apply to dividends of surplus or dividends of profits whose record date for payment falls within a business year ending on or after the Companies Act Effective Date.

②The amount of bonuses for which the obligation has not been determined prescribed in Article 67, paragraph (2) of the Former Corporation Tax Act in a business year that commenced on or after the Effective Date and ended before the Companies Act Effective Date is to be included in the retained amount prescribed in Article 67, paragraph (3) of the New Corporation Tax Act.

The provisions of Article 69, paragraphs (8) and (11) of the New Corporation Tax Act apply in the case where there is an amount of dividends, etc. prescribed in those provisions whose record date for payment is a date on or after the Companies Act Effective Date, and in the case where there is an amount of dividends, etc. prescribed in Article 69, paragraphs (8) and (11) of the Former Corporation Tax Act whose record date for payment is a date before the Companies Act Effective Date, the provisions then in force continue to govern.

The provisions of Article 81-4, paragraph (2) of the New Corporation Tax Act apply to the amount of dividends, etc. prescribed in that paragraph that a consolidated corporation receives whose record date prescribed in that paragraph is a date on or after the Companies Act Effective Date, and with regard to the amount of dividends, etc. prescribed in Article 81-4, paragraph (2) of the Former Corporation Tax Act that a consolidated corporation received for which the last day of the period used as the basis of the calculation is before the Companies Act Effective Date, the provisions then in force continue to govern.

①With regard to the amount of contributions or donations prescribed in Article 81-6, paragraph (1) of the Former Corporation Tax Act that a consolidated corporation paid in a consolidated business year that ended before the Companies Act Effective Date and for which it carried out the accounting treatment prescribed in that paragraph, the provisions then in force continue to govern.

②With regard to the application of the provisions of Article 81-6, paragraph (3) of the Former Corporation Tax Act in the case where a consolidated corporation pays the amount of contributions or donations prescribed in that paragraph in a consolidated business year ending during the period from the Effective Date to the day preceding the Companies Act Effective Date, the phrase "amount of consolidated individual capital, etc." in that paragraph is deemed to be replaced with "amount of consolidated individual stated capital, etc.".

①The provisions of Article 81-9, paragraph (2), item (ii) of the New Corporation Tax Act apply to net operating losses or individually attributed amounts of consolidated losses specified in that item that arose in each business year or each consolidated business year prior to the business year or consolidated business year that includes the date of a share transfer, in the case where the consolidated subsidiary corporation referred to in that paragraph is a wholly owned subsidiary corporation in a share transfer pertaining to a share transfer that does not fall under a qualified share transfer and that it carries out on or after October 1, 2006, and with regard to net operating losses or individually attributed amounts of consolidated losses specified in item (ii) of that paragraph that arose in each business year or each consolidated business year prior to the business year or consolidated business year that includes the date of a share transfer, in the case where the consolidated subsidiary corporation referred to in Article 81-9, paragraph (2) of the Former Corporation Tax Act is a wholly owned subsidiary company prescribed in item (ii) of that paragraph pertaining to a share transfer that it carried out before October 1, 2006, the provisions then in force continue to govern.

②With regard to the application of the provisions of Article 81-9 of the Former Corporation Tax Act to a corporation incorporated through a share transfer during the period from the Companies Act Effective Date until September 30, 2006, the phrase "wholly owned subsidiary company prescribed in Article 352, paragraph (1) (Share Exchange) of the Commercial Code" in paragraph (2), item (ii) of that Article is deemed to be replaced with "wholly owned subsidiary company in share transfer prescribed in Article 773, paragraph (1), item (v) (Share Transfer Plans) of the Companies Act", and the phrase "wholly owning parent company" is deemed to be replaced with "wholly owning parent company incorporated in share transfer prescribed in item (i) of that paragraph".

The provisions of Article 81-9-2 of the New Corporation Tax Act apply to consolidated net operating losses prescribed in paragraph (1) of that Article that arose in each consolidated business year prior to the applicable consolidated business year prescribed in that paragraph, in the case where, on or after the Effective Date, a consolidated corporation comes to have with another person prescribed in that paragraph a specified controlling interest prescribed in that paragraph held by that other person.

①The provisions of Article 81-10, paragraph (1) of the New Corporation Tax Act apply in the case where a consolidated corporation transfers assets for capital gain or loss adjustment prescribed in that paragraph on or after the Effective Date, and in the case where a consolidated corporation transferred assets for capital gain or loss adjustment prescribed in Article 81-10, paragraph (1) of the Former Corporation Tax Act before the Effective Date, the provisions then in force continue to govern.

②In the case where a consolidated corporation held, on the day preceding the Effective Date, assets for capital gain or loss adjustment prescribed in Article 81-10, paragraph (2) of the Former Corporation Tax Act (limited to the shares or capital contributions that the corporation holds in itself), the provisions of that paragraph apply by deeming that the ground referred to in that paragraph arose with regard to those assets for capital gain or loss adjustment on the Effective Date.

The provisions of Article 81-12, paragraphs (1) through (3) of the New Corporation Tax Act apply to corporation tax on consolidated income for consolidated business years for which the consolidated parent corporation business year of a consolidated parent corporation prescribed in those provisions (meaning the consolidated parent corporation business year prescribed in Article 15-2, paragraph (1) of the New Corporation Tax Act; the same applies hereinafter in this Article and the following Article) commences on or after January 1, 2007, and with regard to corporation tax on consolidated income for consolidated business years for which the consolidated parent corporation business year of a consolidated parent corporation prescribed in Article 81-12, paragraphs (1) through (3) of the Former Corporation Tax Act commenced before that date, the provisions then in force continue to govern.

①The provisions of Article 81-13 of the New Corporation Tax Act apply to corporation tax on consolidated income for consolidated business years for which the consolidated parent corporation business year of the consolidated corporation referred to in paragraph (1) of that Article commences on or after the Effective Date, and with regard to corporation tax on consolidated income for consolidated business years for which the consolidated parent corporation business year of the consolidated corporation referred to in Article 81-13, paragraph (1) of the Former Corporation Tax Act commenced before the Effective Date, the provisions then in force continue to govern.

②The provisions of Article 81-13, paragraph (3) of the New Corporation Tax Act apply to dividends of surplus or dividends of profits whose record date for payment falls within a consolidated business year ending on or after the Companies Act Effective Date.

③The amount of bonuses for which the obligation has not been determined prescribed in Article 81-13, paragraph (2) of the Former Corporation Tax Act in a consolidated business year that commenced on or after the Effective Date and ended before the Companies Act Effective Date is to be included in the retained amount prescribed in Article 81-13, paragraph (2) of the New Corporation Tax Act.

The provisions of Article 81-15, paragraphs (8) and (11) of the New Corporation Tax Act apply in the case where there is an amount of dividends, etc. prescribed in those provisions whose record date for payment is a date on or after the Companies Act Effective Date, and in the case where there is an amount of dividends, etc. prescribed in Article 81-15, paragraphs (8) and (11) of the Former Corporation Tax Act whose record date for payment is a date before the Companies Act Effective Date, the provisions then in force continue to govern.

The provisions of Article 82-4 of the New Corporation Tax Act apply to corporation tax on income for calculation periods of a corporation that is the trustee of a specified trust commencing on or after January 1, 2007, and with regard to corporation tax on income for calculation periods of a corporation that is the trustee of a specified trust that commenced before that date, the provisions then in force continue to govern.

The provisions of Article 99, paragraphs (1) and (2) and Article 102, paragraph (1) of the New Corporation Tax Act apply to corporation tax on liquidation income resulting from the dissolution of a corporation (excluding dissolution due to a merger; the same applies hereinafter in this Article) on or after January 1, 2007 (including corporation tax on income for a business year in liquidation of a corporation that is subject to corporation tax on liquidation income and corporation tax to be paid due to a partial distribution of residual assets; the same applies hereinafter in this Article), and with regard to corporation tax on liquidation income resulting from the dissolution of a corporation before that date, the provisions then in force continue to govern.

①The provisions of Article 132, paragraph (3) of the New Corporation Tax Act apply to acts or calculations carried out by a corporation on or after the Effective Date.

②The provisions of Article 132-2 of the New Corporation Tax Act apply to acts or calculations carried out by a corporation on or after October 1, 2006, and with regard to acts or calculations carried out by a corporation before that date, the provisions then in force continue to govern.

The provisions of Article 143, paragraphs (1) through (3) of the New Corporation Tax Act apply to corporation tax on income for business years of a foreign corporation commencing on or after January 1, 2007, and with regard to corporation tax on income for business years of a foreign corporation that commenced before that date, the provisions then in force continue to govern.

The provisions of Article 145-4 of the New Corporation Tax Act apply to corporation tax on income for calculation periods of a foreign corporation that is the trustee of a specified trust commencing on or after January 1, 2007, and with regard to corporation tax on income for calculation periods of a foreign corporation that is the trustee of a specified trust that commenced before that date, the provisions then in force continue to govern.

With regard to public notices given by a district director pursuant to the provisions of Article 152 of the Former Corporation Tax Act before the Effective Date, the provisions then in force continue to govern.

With regard to the application of penal provisions to acts committed before this Act (or, for the provisions set forth in the items of Article 1 of the Supplementary Provisions, those provisions; the same applies hereinafter in this Article) comes into effect and to acts committed after this Act comes into effect in the cases where the provisions then in force continue to govern pursuant to the provisions of these Supplementary Provisions, the provisions then in force continue to govern.

Beyond what is provided for in these Supplementary Provisions, transitional measures necessary in connection with the enforcement of this Act are specified by Cabinet Order.