This Act comes into effect on April 1, 2009.

The provisions of Article 23-2 of the Corporation Tax Act as amended by the provisions of Article 2 (hereinafter referred to as the "New Corporation Tax Act" up to Article 60 of the Supplementary Provisions) apply to the amount of dividends of surplus, etc. prescribed in paragraph (1) of that Article that a domestic corporation receives from a foreign subsidiary prescribed in that paragraph in a business year starting on or after the Effective Date.

①The provisions of Article 26, paragraph (2) of the New Corporation Tax Act apply to the amount of foreign withholding tax, etc. prescribed in that paragraph that is reduced in a business year of a domestic corporation starting on or after the Effective Date.

②The provisions of Article 26, paragraph (3) of the New Corporation Tax Act apply to the amount of foreign country's corporate tax prescribed in Article 69, paragraph (1) of the New Corporation Tax Act that is reduced in a business year of a domestic corporation starting on or after the Effective Date, and with regard to the amount of foreign country's corporate tax prescribed in Article 69, paragraph (1) of the Corporation Tax Act prior to the amendment by the provisions of Article 2 (hereinafter referred to as the "Former Corporation Tax Act" up to Article 60 of the Supplementary Provisions) that was reduced in a business year of a domestic corporation that started before the Effective Date, the provisions then in force continue to govern.

With regard to the amount of foreign country's corporate tax imposed on the income of a foreign subsidiary prescribed in Article 69, paragraph (8) of the Former Corporation Tax Act (including an amount deemed to be the amount of foreign country's corporate tax prescribed in paragraph (8) of that Article pursuant to the provisions of paragraph (9) of that Article), where a domestic corporation is subject to the provisions of that paragraph, which remain in force pursuant to the provisions of Article 12, paragraph (2) of the Supplementary Provisions, in each business year starting on or before the day on which three years have elapsed from the Effective Date, the provisions of Article 28 of the Former Corporation Tax Act remain in force. In this case, the phrase "Article 69, paragraph (8)" in that Article is deemed to be replaced with "Article 69, paragraph (8) 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), which remains in force pursuant to the provisions of Article 12, paragraph (2) (Transitional Measures Concerning Foreign Tax Credit) of the Supplementary Provisions of that Act".

①The provisions of Article 33, paragraphs (2) and (3) of the New Corporation Tax Act apply to a revaluation prescribed in Article 33, paragraphs (2) and (3) of the New Corporation Tax Act that a corporation (including an association or foundation without juridical personality prescribed in Article 2, item (viii) of the New Corporation Tax Act; hereinafter the same applies in this paragraph) carries out on or after the Effective Date, and with regard to a revaluation prescribed in Article 33, paragraph (2) of the Former Corporation Tax Act that a corporation carried out before the Effective Date, the provisions then in force continue to govern.

②The provisions of Article 33, paragraph (4) of the New Corporation Tax Act apply in the case where the facts prescribed in that paragraph occur on or after the Effective Date, and with regard to the case where the facts prescribed in Article 33, paragraph (3) of the Former Corporation Tax Act occurred before the Effective Date, the provisions then in force continue to govern.

The provisions of Article 39-2 of the New Corporation Tax Act apply to the amount of foreign withholding tax, etc. prescribed in that Article pertaining to the amount of dividends of surplus, etc. prescribed in that Article that a domestic corporation receives in a business year starting on or after the Effective Date.

①The provisions of Article 55, paragraph (4) of the New Corporation Tax Act (limited to the part concerning item (iii) of that paragraph) apply to those listed in that item pertaining to an act that ended on or after the Effective Date, and with regard to those listed in Article 55, paragraph (4), item (iii) of the Former Corporation Tax Act pertaining to an act that ended before the Effective Date, the provisions then in force continue to govern.

②In the case referred to in the preceding paragraph, when applying the provisions of Article 55, paragraph (4) of the New Corporation Tax Act to those listed in item (iii) of that paragraph (excluding a surcharge and delinquent charge under the provisions of the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade; hereinafter referred to as a "foreign surcharge" in this paragraph) pertaining to an act that commenced before the Effective Date and ended on or after the Effective Date, the portion of the amount of the foreign surcharge that pertains to the part of the act before the Effective Date is deemed not to fall under the amount of those listed in that item.

①The provisions of Article 69, paragraph (1) of the New Corporation Tax Act apply to foreign country's corporate tax prescribed in that paragraph that becomes payable in a business year of a domestic corporation starting on or after the Effective Date, and with regard to foreign country's corporate tax prescribed in Article 69, paragraph (1) of the Former Corporation Tax Act that became payable in a business year of a domestic corporation that started before the Effective Date, the provisions then in force continue to govern.

②In the case where a domestic corporation has received, in a business year that started before the Effective Date, an amount of dividends, etc. prescribed in Article 69, paragraph (8) of the Former Corporation Tax Act (hereinafter referred to as the "amount of dividends, etc." in this paragraph) from a foreign subsidiary prescribed in that paragraph (including the case where it has received, in a consolidated business year that started before the Effective Date, an amount of dividends, etc. from a foreign subsidiary prescribed in Article 81-15, paragraph (8) of the Former Corporation Tax Act), with regard to the portion pertaining to such amount of dividends, etc. of the amount of foreign country's corporate tax (meaning foreign country's corporate tax prescribed in Article 69, paragraph (1) of the Former Corporation Tax Act; hereinafter the same applies in this paragraph) imposed on the income of a foreign subsidiary prescribed in Article 69, paragraph (8) of the Former Corporation Tax Act (including the amount of foreign country's corporate tax imposed on the income of a foreign subsidiary prescribed in Article 81-15, paragraph (8) of the Former Corporation Tax Act) and of the amount of foreign country's corporate tax imposed on the income of a foreign second-tier subsidiary prescribed in Article 69, paragraph (11) of the Former Corporation Tax Act (including the amount of foreign country's corporate tax imposed on the income of a foreign second-tier subsidiary prescribed in Article 81-15, paragraph (11) of the Former Corporation Tax Act) in each business year of the domestic corporation starting on or before the day on which three years have elapsed from the Effective Date, the provisions of Article 69, paragraphs (8), (9), (11) through (13) and (15) through (18) of the Former Corporation Tax Act remain in force. In this case, the phrase "Article 81-15, paragraph (8)" in paragraph (9) of that Article is deemed to be replaced with "Article 81-15, paragraph (8) 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), which remains in force pursuant to the provisions of Article 16, paragraph (2) (Transitional Measures Concerning Foreign Tax Credit in Consolidated Business Years) of the Supplementary Provisions of that Act", the phrase "Article 81-15, paragraph (8)" in paragraph (12) of that Article is deemed to be replaced with "Article 81-15, paragraph (8) of the Corporation Tax Act prior to the amendment by the provisions of Article 2 of the Act Partially Amending the Income Tax Act, etc. (Act No. 13 of 2009), which remains in force pursuant to the provisions of Article 16, paragraph (2) of the Supplementary Provisions of that Act", and the phrase "Article 28" in paragraph (13) of that Article is deemed to be replaced with "Article 28 of the Corporation Tax Act prior to the amendment by the provisions of Article 2 of the Act Partially Amending the Income Tax Act, etc. (Act No. 13 of 2009), which remains in force pursuant to the provisions of Article 8 (Transitional Measures Concerning Inclusion in Gross Profits of a Foreign Subsidiary's Foreign Tax That Is Credited Against the Corporation Tax) of the Supplementary Provisions of that Act".

③The provisions of Article 69, paragraph (8) of the New Corporation Tax Act apply to the amount of foreign country's corporate tax prescribed in paragraph (1) of that Article that is reduced in a business year of a domestic corporation starting on or after the Effective Date, and with regard to the amount of foreign country's corporate tax prescribed in Article 69, paragraph (1) of the Former Corporation Tax Act that was reduced in a business year of a domestic corporation that started before the Effective Date, the provisions then in force continue to govern.

④The provisions of Article 69, paragraph (10) of the New Corporation Tax Act apply in the case where a domestic corporation is subject to the provisions of paragraph (1) of that Article in a business year starting on or after the Effective Date, and with regard to the case where a domestic corporation was subject to the provisions of Article 69, paragraph (1) of the Former Corporation Tax Act in a business year that started before the Effective Date, the provisions then in force continue to govern.

⑤The provisions of Article 69, paragraph (11) of the New Corporation Tax Act apply in the case where a domestic corporation is subject to the provisions of paragraph (2) or (3) of that Article in a business year starting on or after the Effective Date, and with regard to the case where a domestic corporation was subject to the provisions of Article 69, paragraph (2) or (3) of the Former Corporation Tax Act in a business year that started before the Effective Date, the provisions then in force continue to govern.

⑥The provisions of Article 69, paragraph (12) of the New Corporation Tax Act apply in the case where a domestic corporation is subject to the provisions of paragraphs (1) through (3) of that Article in a business year starting on or after the Effective Date, and with regard to the case where a domestic corporation was subject to the provisions of Article 69, paragraphs (1) through (3) of the Former Corporation Tax Act in a business year that started before the Effective Date, the provisions then in force continue to govern.

The provisions of Article 70 of the New Corporation Tax Act apply to the amount of corporation tax based on fictitious accounting prescribed in that Article pertaining to a reassessment under that Article made on or after the Effective Date, and with regard to the amount of corporation tax reduced by a reassessment prescribed in Article 70, paragraph (1) of the Former Corporation Tax Act or a reassessment reducing the amount of income for each business year prescribed in paragraph (2) of that Article made before the Effective Date, the provisions then in force continue to govern.

The provisions of Article 81-5 of the New Corporation Tax Act apply to the amount of foreign country's corporate tax prescribed in Article 69, paragraph (1) of the New Corporation Tax Act that is reduced in a consolidated business year of a consolidated corporation starting on or after the Effective Date, and with regard to the amount of foreign country's corporate tax prescribed in Article 69, paragraph (1) of the Former Corporation Tax Act that was reduced in a consolidated business year of a consolidated corporation that started before the Effective Date, the provisions then in force continue to govern.

With regard to the amount of foreign country's corporate tax imposed on the income of a foreign subsidiary prescribed in Article 81-15, paragraph (8) of the Former Corporation Tax Act (including an amount deemed to be the amount of foreign country's corporate tax prescribed in paragraph (8) of that Article pursuant to the provisions of paragraph (9) of that Article), where a consolidated corporation is subject to the provisions of that paragraph, which remain in force pursuant to the provisions of paragraph (2) of the following Article, in each consolidated business year starting on or before the day on which three years have elapsed from the Effective Date, the provisions of Article 81-5 of the Former Corporation Tax Act remain in force. In this case, the phrase "Article 81-15, paragraph (8)" in that Article is deemed to be replaced with "Article 81-15, paragraph (8) 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), which remains in force pursuant to the provisions of Article 16, paragraph (2) (Transitional Measures Concerning Foreign Tax Credit in Consolidated Business Years) of the Supplementary Provisions of that Act".