①The provisions of Article 134-2 of the New Corporation Tax Act (excluding the part pertaining to paragraph (4)) apply to the amount of corporation tax based on fictitious accounting prescribed in paragraph (1) of that Article pertaining to a Reassessment made on or after the Effective Date, and with regard to the amount that may be deducted pursuant to the provisions of Article 70, paragraph (1) or Article 81-16, paragraph (1) (including as applied mutatis mutandis pursuant to paragraph (2) of that Article) of the Former Corporation Tax Act pertaining to a Reassessment prescribed in Article 134-2, paragraph (1) or (2) of the Former Corporation Tax Act made before the Effective Date, the provisions then in force continue to govern.

②The provisions of Article 134-2 of the New Corporation Tax Act (limited to the part pertaining to paragraph (4)) apply to the facts listed in the items of that paragraph that arise on or after the Effective Date. In such a case, when applying the provisions of that Article (limited to the part pertaining to that paragraph) to the amount of corporation tax reduced by a Reassessment made before the Effective Date, the phrase "with regard to an applicable corporation" in that paragraph is deemed to be replaced with "with regard to a domestic corporation to which the provisions of Article 70, paragraph (1) (Corporation Tax Credit Due to a Reassessment after Fictitious Accounting) or Article 81-16, paragraph (1) (Corporation Tax Credit in Consolidated Business Years Due to a Reassessment after Fictitious Accounting) (including as applied mutatis mutandis pursuant to paragraph (2) of that Article; the same applies hereinafter in this paragraph) of the Corporation Tax Act prior to the amendment by the provisions of Article 2 (Partial Amendment of the Corporation Tax Act) of the Act Partially Amending the Income Tax Act, etc. (Act No. 13 of 2009) (hereinafter referred to as the "Former Corporation Tax Act" in this paragraph) apply (hereinafter referred to as an "applicable corporation" in this Article)", and the phrase "the amount of corporation tax based on fictitious accounting (excluding the amount that has already become refundable pursuant to the provisions of the preceding two paragraphs or paragraph (7) and the amount deducted pursuant to the provisions of Article 70 or Article 81-16; the same applies in paragraphs (6) and (7))" is deemed to be replaced with "the amount that may be deducted pursuant to the provisions of Article 70, paragraph (1) or Article 81-16, paragraph (1) of the Former Corporation Tax Act (excluding the amount that has already become refundable pursuant to the provisions of paragraph (7) and the amount deducted pursuant to the provisions of Article 70, paragraph (1) or Article 81-16, paragraph (1) of the Former Corporation Tax Act; referred to as the "amount of corporation tax based on fictitious accounting" in paragraphs (6) and (7))".