①The provisions of Article 23-2 of the New Corporation Tax Act 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 beginning on or after April 1, 2016, and with regard to the amount of dividends of surplus, etc. prescribed in Article 23-2, 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") that a domestic corporation received from a foreign subsidiary prescribed in that paragraph in a business year that began before that date, the provisions then in force continue to govern.

②With regard to the application of the provisions of Article 23-2 of the New Corporation Tax Act for each business year of a domestic corporation beginning during the period from April 1, 2016 to March 31, 2018, the phrase "the amount of dividends of surplus, etc. received from a foreign subsidiary" in paragraph (2), item (i) and paragraph (3) of that Article is deemed to be replaced with "the amount of dividends of surplus, etc. received from a foreign subsidiary (excluding those pertaining to shares or capital contributions of the foreign subsidiary held as of April 1, 2016 (limited to shares or capital contributions of a foreign corporation that falls under the category of foreign subsidiary as of that date))".