①The provisions of Article 81-9, paragraph (1) of the New Corporation Tax Act apply to corporation tax on consolidated income for a consolidated business year for which the consolidated parent corporation business year of the consolidated parent corporation starts on or after the Effective Date, and with regard to corporation tax on consolidated income for a consolidated business year for which the consolidated parent corporation business year of the consolidated parent corporation started before the Effective Date, the provisions then in force continue to govern.

②The provisions of Article 81-9, paragraph (2) (limited to the part pertaining to item (i)) and paragraph (3) (limited to the part pertaining to item (i)) of the New Corporation Tax Act apply to the net operating loss or individually attributed amount of consolidated operating loss specified in that item of a consolidated parent corporation or a specified consolidated subsidiary corporation prescribed in Article 81-9, paragraph (2), item (i) of the New Corporation Tax Act for which the first day of the consolidated parent corporation's business year containing the consolidation approval date (meaning the day on which the approval set forth in Article 4-2 of the New Corporation Tax Act took effect; the same applies hereinafter in this Article) is on or after the Effective Date.

③In the case referred to in the preceding paragraph, with regard to the application of the provisions of Article 57, paragraph (9) or Article 58, paragraph (4) of the Corporation Tax Act Before the October Changes when a company split by split-off or a merger in which the specified consolidated subsidiary corporation prescribed in that paragraph is the splitting corporation or the acquired corporation is effected during the period from the Effective Date to September 30, 2010, the phrase "consolidated subsidiary corporation prescribed in Article 81-9, paragraph (2), item (ii)" in Article 57, paragraph (9), item (i), (b) and item (ii), (b) of the Corporation Tax Act Before the October Changes is deemed to be replaced with "specified consolidated subsidiary corporation prescribed in Article 81-9, paragraph (2), item (i)".

④With regard to the net operating loss or individually attributed amount of consolidated operating loss specified in Article 81-9, paragraph (2), item (i) or (ii) of the Former Corporation Tax Act of a consolidated parent corporation or consolidated subsidiary corporation for which the first day of the consolidated parent corporation's business year containing the consolidation approval date was before the Effective Date, the provisions of that paragraph (limited to the part pertaining to item (i) or (ii)) remain in force.

⑤In the case referred to in the preceding paragraph, with regard to the application of the provisions of Article 57, paragraph (9) or Article 58, paragraph (4) of the Corporation Tax Act Before the October Changes when a company split by split-off in which the consolidated subsidiary corporation prescribed in that paragraph is the splitting corporation is effected during the period from the Effective Date to September 30, 2010, or when a merger in which the consolidated subsidiary corporation prescribed in that paragraph is the acquired corporation is effected during the period from the Effective Date to the last day of the consolidated parent corporation business year referred to in that paragraph, the phrase "consolidated subsidiary corporation prescribed in Article 81-9, paragraph (2), item (ii)" in Article 57, paragraph (9), item (i), (b) and item (ii), (b) of the Corporation Tax Act Before the October Changes is deemed to be replaced with "consolidated subsidiary corporation prescribed in Article 81-9, paragraph (2), item (ii) (Carryover of Consolidated Losses) 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. 6 of 2010), which remains in force pursuant to the provisions of Article 26, paragraph (4) (Transitional Measures Concerning Carryover of Consolidated Losses) of the Supplementary Provisions of that Act".

⑥The provisions of Article 81-9, paragraph (2) (limited to the part pertaining to item (ii)) and paragraph (3) (limited to the part pertaining to item (ii)) of the New Corporation Tax Act apply to the net operating loss or individually attributed amount of consolidated operating loss specified in that item in the case where a qualified merger prescribed in paragraph (2), item (ii) of that Article is effected within the period of a consolidated parent corporation business year of the consolidated parent corporation or consolidated subsidiary corporation prescribed in paragraph (2) of that Article starting on or after the Effective Date (limited to the period on or after October 1, 2010), or in the case where the residual assets of another domestic corporation prescribed in that item (limited to one that dissolves on or after October 1, 2010) are determined within the period of a consolidated parent corporation business year of that consolidated parent corporation or consolidated subsidiary corporation starting on or after the Effective Date.

⑦With regard to the net operating loss or individually attributed amount of consolidated operating loss specified in Article 81-9, paragraph (2), item (iii) of the Former Corporation Tax Act in the case where a consolidated parent corporation effected a qualified merger within the period of a consolidated parent corporation business year that started before the Effective Date (including the period on or before September 30, 2010 of a consolidated parent corporation business year starting on or after the Effective Date), or in the case where a consolidated parent corporation effected a quasi-merger Qualified Company Split by Split-Off prescribed in Article 57, paragraph (2) of the Former Corporation Tax Act on or before September 30, 2010, the provisions of that paragraph (limited to the part pertaining to that item) remain in force.

⑧With regard to the application of the provisions of Article 81-9, paragraph (2) of the New Corporation Tax Act during the period from the Effective Date to September 30, 2010, the phrase "Article 58, paragraph (4)" in item (i) of that paragraph is deemed to be replaced with "Article 58, paragraph (6)", the phrase "paragraph (5)" in (a) of that item with "paragraph (6)", the phrase "paragraph (4) or (8) of that Article" with "paragraph (5) or (9) of that Article", and the phrase "paragraph (3) of that Article" with "paragraph (4) of that Article".

⑨With regard to the net operating loss prescribed in Article 81-9, paragraph (3) of the Former Corporation Tax Act in the case where a consolidated corporation effected a merger or a company split by split-off on or before September 30, 2010, the provisions of that paragraph remain in force. In such a case, when the consolidated parent corporation business year containing the day preceding the date of that company split by split-off started before the Effective Date, the phrase "item (ii) of the preceding paragraph" in that paragraph is deemed to be replaced with "Article 81-9, paragraph (2), item (ii) (Carryover of Consolidated Losses) 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. 6 of 2010), which remains in force pursuant to the provisions of Article 26, paragraph (4) (Transitional Measures Concerning Carryover of Consolidated Losses) of the Supplementary Provisions of that Act", and when the consolidated parent corporation business year containing that preceding day starts on or after the Effective Date, the phrase "consolidated subsidiary corporation prescribed in item (ii) of the preceding paragraph" in that paragraph is deemed to be replaced with "specified consolidated subsidiary corporation prescribed in item (i) of the preceding paragraph".

⑩The provisions of Article 81-9, paragraph (5) of the Corporation Tax Act as Amended for October (limited to the part pertaining to the consolidated subsidiary corporation referred to in item (iii) of that paragraph) apply to the individually attributed amount of consolidated operating loss specified in that item in the case where the day on which a qualified reorganization, etc. prescribed in that item in which the consolidated subsidiary corporation is the acquiring corporation, etc. prescribed in that item is effected is a day on or after October 1, 2010 (excluding a day within the period on or after October 1, 2010 of a consolidated parent corporation business year that started before the Effective Date).

⑪The provisions of Article 81-9-2, paragraph (2) of the New Corporation Tax Act (limited to the part pertaining to item (i)) apply to the amount of unappropriated loss or individually attributed amount of consolidated operating loss listed in that item in the case where a qualified merger prescribed in that item is effected within the period of a consolidated parent corporation business year of the consolidated parent corporation or consolidated subsidiary corporation prescribed in that paragraph starting on or after the Effective Date (limited to the period on or after October 1, 2010).

⑫With regard to the amount of unappropriated loss or individually attributed amount of consolidated operating loss listed in Article 81-9-2, paragraph (2), item (i) of the Former Corporation Tax Act in the case where a consolidated parent corporation effected a qualified merger within the period of a consolidated parent corporation business year that started before the Effective Date (including the period on or before September 30, 2010 of a consolidated parent corporation business year starting on or after the Effective Date), or in the case where a consolidated parent corporation effected a quasi-merger Qualified Company Split by Split-Off prescribed in Article 57, paragraph (2) of the Former Corporation Tax Act on or before September 30, 2010, the provisions of that paragraph (limited to the part pertaining to that item) remain in force. In such a case, the phrase "paragraph (2), item (iii) of the preceding Article" in that item is deemed to be replaced with "Article 81-9, paragraph (2), item (iii) (Carryover of Consolidated Losses) 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. 6 of 2010), which remains in force pursuant to the provisions of Article 26, paragraph (7) (Transitional Measures Concerning Carryover of Consolidated Losses) of the Supplementary Provisions of that Act".

⑬The provisions of Article 81-10, paragraph (2) of the Corporation Tax Act as Amended for October (limited to the part pertaining to the consolidated subsidiary corporation referred to in item (ii) of that paragraph) apply to the individually attributed amount of consolidated operating loss listed in that item in the case where the day on which a qualified reorganization, etc. prescribed in that item in which the consolidated subsidiary corporation is the acquiring corporation, succeeding corporation in a company split, corporation receiving a capital contribution in kind or corporation receiving a distribution in kind is effected is a day on or after October 1, 2010 (excluding a day within the period on or after October 1, 2010 of a consolidated parent corporation business year that started before the Effective Date).

⑭The provisions of Article 81-9-2, paragraph (3) of the New Corporation Tax Act apply to the amount of unappropriated loss or individually attributed amount of consolidated operating loss prescribed in that paragraph in the case where the residual assets of a domestic corporation prescribed in that paragraph (limited to one that dissolves on or after October 1, 2010) are determined within the period of a consolidated parent corporation business year of the consolidated corporation showing a loss, etc. referred to in that paragraph starting on or after the Effective Date.

⑮The provisions of Article 81-9-2, paragraph (4) of the New Corporation Tax Act apply to the net operating loss or individually attributed amount of consolidated operating loss prescribed in that paragraph of a consolidated parent corporation or specified consolidated subsidiary corporation prescribed in that paragraph for which the first day of the consolidated parent corporation's business year containing the consolidation approval date is on or after the Effective Date.

⑯With regard to the net operating loss or individually attributed amount of consolidated operating loss prescribed in Article 81-9-2, paragraph (3) of the Former Corporation Tax Act of a consolidated parent corporation or consolidated subsidiary corporation prescribed in that paragraph for which the first day of the consolidated parent corporation's business year containing the consolidation approval date was before the Effective Date, the provisions of that paragraph remain in force. In such a case, the phrase "paragraph (2) of the preceding Article" in that paragraph is deemed to be replaced with "Article 81-9, paragraph (2) (Carryover of Consolidated Losses) 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. 6 of 2010), which remains in force pursuant to the provisions of Article 26, paragraph (4) (Transitional Measures Concerning Carryover of Consolidated Losses) of the Supplementary Provisions of that Act".

⑰The provisions of Article 81-9-2, paragraph (5) of the New Corporation Tax Act apply to the amount of unappropriated loss or individually attributed amount of consolidated operating loss prescribed in that paragraph in the case where a qualified merger prescribed in that paragraph is effected within the period of a consolidated parent corporation business year of the consolidated parent corporation or consolidated subsidiary corporation prescribed in that paragraph starting on or after the Effective Date (limited to the period on or after October 1, 2010), or in the case where the residual assets of a corporation showing a loss, etc. or consolidated corporation showing a loss, etc. that is another domestic corporation prescribed in that paragraph (limited to one that dissolves on or after October 1, 2010) are determined within the period of a consolidated parent corporation business year of that consolidated parent corporation starting on or after the Effective Date.

⑱With regard to the amount of unappropriated loss or individually attributed amount of consolidated operating loss prescribed in Article 81-9-2, paragraph (4) of the Former Corporation Tax Act in the case where a consolidated parent corporation effected a qualified merger within the period of a consolidated parent corporation business year that started before the Effective Date (including the period on or before September 30, 2010 of a consolidated parent corporation business year starting on or after the Effective Date), or in the case where a consolidated parent corporation effected a quasi-merger Qualified Company Split by Split-Off prescribed in Article 57, paragraph (2) of the Former Corporation Tax Act on or before September 30, 2010, the provisions of that paragraph remain in force. In such a case, the phrase "item (iii), (a) of that paragraph" in that paragraph is deemed to be replaced with "Article 81-9, paragraph (2), item (iii), (a) (Carryover of Consolidated Losses) 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. 6 of 2010), which remains in force pursuant to the provisions of Article 26, paragraph (7) (Transitional Measures Concerning Carryover of Consolidated Losses) of the Supplementary Provisions of that Act".