This Act comes into effect on April 1, 2014; provided, however, that the provisions set forth in the following items come into effect on the dates specified in those items:

Except as otherwise provided for in these Supplementary Provisions, the provisions of the Corporation Tax Act as amended by Article 3 (hereinafter referred to as the "New Corporation Tax Act") concerning corporation tax for foreign corporations apply to corporation tax on income for business years of a foreign corporation beginning on or after April 1, 2016, and the provisions then in force continue to govern corporation tax on income for business years of a foreign corporation that began before that date.

①The provisions of Article 10-3, paragraph (3) of the New Corporation Tax Act apply in the case where a foreign corporation that has a permanent establishment ceases to have a permanent establishment in a business year beginning on or after April 1, 2016.

②The provisions of Article 10-3, paragraph (4) of the New Corporation Tax Act apply in the case where a foreign corporation that does not have a permanent establishment comes to have a permanent establishment on or after April 1, 2016.

The provisions of Article 14, paragraph (1), items (xxiii) through (xxv) of the New Corporation Tax Act apply in the case where the facts prescribed in those provisions occur on or after April 1, 2016, and the provisions then in force continue to govern the case where the facts prescribed in Article 14, paragraph (1), items (xxiii) through (xxv) of the Corporation Tax Act prior to the amendment by Article 3 (hereinafter referred to as the "Former Corporation Tax Act") occurred before that date.

The provisions of Article 69 of the New Corporation Tax Act (excluding the part pertaining to the local corporation tax credit limit prescribed in paragraph (2) of that Article) apply to corporation tax on income for business years of a domestic corporation beginning on or after April 1, 2016, and the provisions then in force continue to govern corporation tax on income for business years of a domestic corporation that began before that date.

The provisions of Article 81-15 of the New Corporation Tax Act (excluding the part pertaining to the individually attributed amount of the local corporation tax credit limit prescribed in paragraph (2) of that Article) apply to corporation tax on consolidated income for consolidated business years of a consolidated corporation for which the consolidated parent corporation's business year prescribed in Article 15-2, paragraph (1) of the New Corporation Tax Act begins on or after April 1, 2016, and the provisions then in force continue to govern corporation tax on consolidated income for consolidated business years of a consolidated corporation for which the consolidated parent corporation's business year prescribed in Article 15-2, paragraph (1) of the Former Corporation Tax Act began before that date.

The provisions of Article 142-8 of the New Corporation Tax Act apply in the case where a foreign corporation that has a permanent establishment ceases to have a permanent establishment in a business year beginning on or after April 1, 2016.

①With regard to the application of the provisions of Article 144-3 of the New Corporation Tax Act for the business year of a foreign corporation (limited to an ordinary corporation; the same applies hereinafter in this Article) that includes the day on which six months have elapsed, in the case where the period of the first business year of that foreign corporation beginning on or after April 1, 2016 (hereinafter referred to as the "first business year" in this Article) includes a day on which six months have elapsed (meaning the day on which six months have elapsed from the day of commencement of the first business year of the foreign corporation; the same applies hereinafter in this Article), the phrase "Article 144-6, paragraph (1), item (vii)" in paragraph (1), item (i) of that Article is deemed to be replaced with "Article 74, paragraph (1), item (ii) of the Corporation Tax Act prior to the amendment by Article 3 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014) (hereinafter referred to as the 'Former Corporation Tax Act' in this item and item (i) of the following paragraph) as applied mutatis mutandis pursuant to Article 145, paragraph (1) (Filing of Returns, Payment and Refunds) of the Former Corporation Tax Act", and the phrase "Article 144-6, paragraph (2), item (ii)" in paragraph (2), item (i) of that Article is deemed to be replaced with "Article 74, paragraph (1), item (ii) of the Former Corporation Tax Act as applied mutatis mutandis pursuant to Article 145, paragraph (1) of the Former Corporation Tax Act".

②With regard to the application of the provisions of Article 144-4 of the New Corporation Tax Act for the business year of a foreign corporation (excluding a trust corporation prescribed in Article 4-7 of the New Corporation Tax Act) that includes the day on which six months have elapsed, in the case where the period of the first business year of that foreign corporation includes a day on which six months have elapsed, the phrase "the items of paragraph (1) of the preceding Article" in paragraph (1) of that Article is deemed to be replaced with "the items of Article 71, paragraph (1) (Interim Return) of the Corporation Tax Act prior to the amendment by Article 3 of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014) (hereinafter referred to as the 'Former Corporation Tax Act' in this paragraph and the following paragraph) as applied mutatis mutandis pursuant to Article 145, paragraph (1) (Filing of Returns, Payment and Refunds) of the Former Corporation Tax Act", and the phrase "the items of paragraph (2) of the preceding Article" in paragraph (2) of that Article is deemed to be replaced with "the items of Article 71, paragraph (1) of the Former Corporation Tax Act as applied mutatis mutandis pursuant to Article 145, paragraph (1) of the Former Corporation Tax Act".

③With regard to the application of the provisions of Article 144-5 of the New Corporation Tax Act for the business year of a foreign corporation that includes the day on which six months have elapsed, in the case where the period of the first business year of that foreign corporation includes a day on which six months have elapsed, the phrase "the items of Article 144-3, paragraph (1)" in item (i) of that Article is deemed to be replaced with "the items of Article 144-3, paragraph (1) with the terms replaced pursuant to the provisions of Article 31, paragraph (1) (Transitional Measures Concerning Interim Returns, etc.) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 10 of 2014; referred to as the '2014 Amendment Act' in the following item)", and the phrase "the items of Article 144-3, paragraph (2)" in item (ii) of that Article is deemed to be replaced with "the items of Article 144-3, paragraph (2) with the terms replaced pursuant to the provisions of Article 31, paragraph (1) of the Supplementary Provisions of the 2014 Amendment Act".

A disposition of extension of the due date for filing under Article 75, paragraph (1) or Article 75-2, paragraph (1) of the Former Corporation Tax Act as applied mutatis mutandis pursuant to Article 145, paragraph (1) of the Former Corporation Tax Act that a foreign corporation received in a business year that began before April 1, 2016 is deemed to be a disposition of extension of the due date for filing under Article 75, paragraph (1) of the New Corporation Tax Act as applied mutatis mutandis pursuant to Article 144-7 of the New Corporation Tax Act or under Article 75-2, paragraph (1) of the New Corporation Tax Act as applied mutatis mutandis pursuant to Article 144-8 of the New Corporation Tax Act.

①The provisions of Article 144-13 of the New Corporation Tax Act apply to a net operating loss incurred in a business year of a foreign corporation beginning on or after April 1, 2016, and the provisions then in force continue to govern a net operating loss incurred in a business year of a foreign corporation that began before that date.

①The provisions of Article 122, paragraph (2) of the New Corporation Tax Act as applied mutatis mutandis pursuant to Article 146, paragraph (1) of the New Corporation Tax Act apply to the submission of the application form prescribed in Article 122, paragraph (1) of the New Corporation Tax Act in the case where a business year of a foreign corporation beginning on or after April 1, 2016 falls under any of the business years listed in the items of Article 122, paragraph (2) of the New Corporation Tax Act, and the provisions then in force continue to govern the submission of the application form prescribed in Article 122, paragraph (1) of the Former Corporation Tax Act in the case where a business year of a foreign corporation that began before that date falls under any of the business years listed in the items of Article 122, paragraph (2) of the Former Corporation Tax Act as applied mutatis mutandis pursuant to Article 146, paragraph (1) of the Former Corporation Tax Act.

②The provisions of Article 123 of the New Corporation Tax Act as applied mutatis mutandis pursuant to Article 146, paragraph (1) of the New Corporation Tax Act apply in the case where there are facts falling under item (ii) of that Article with regard to the books and documents pertaining to each business year on or after a business year of a foreign corporation beginning on or after April 1, 2016, and the provisions then in force continue to govern the case where there are facts falling under item (ii) of Article 123 of the Former Corporation Tax Act as applied mutatis mutandis pursuant to Article 146, paragraph (1) of the Former Corporation Tax Act with regard to the books and documents pertaining to each business year on or before a business year of a foreign corporation that began before that date.

③The provisions of Article 127, paragraph (1) of the New Corporation Tax Act as applied mutatis mutandis pursuant to Article 146, paragraph (1) of the New Corporation Tax Act apply to the rescission of approval prescribed in that paragraph pertaining to a business year of a foreign corporation beginning on or after April 1, 2016, and the provisions then in force continue to govern the rescission of approval prescribed in Article 127, paragraph (1) of the Former Corporation Tax Act as applied mutatis mutandis pursuant to Article 146, paragraph (1) of the Former Corporation Tax Act pertaining to a business year of a foreign corporation that began before that date.

The provisions of Article 147-2 of the New Corporation Tax Act apply to acts or calculations made on or after April 1, 2016 that pertain to corporation tax on income pertaining to income attributable to a permanent establishment prescribed in that Article for a business year of a foreign corporation beginning on or after that date.

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.