①In the case where the approval under Article 4-2 of the Former Corporation Tax Act of a domestic corporation has been revoked pursuant to the provisions of Article 4-5, paragraph (2) of the Former Corporation Tax Act (including the case where the approval under Article 4-2 of the Former Corporation Tax Act has been revoked as governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (2) of the Supplementary Provisions; referred to as the "case of revocation of approval" in this paragraph), where it has received the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act (including the case where it has received the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act as governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (3) of the Supplementary Provisions; referred to as the "case of approval of withdrawal" in this paragraph), or where the provisions of Article 29, paragraph (1) or (2) of the Supplementary Provisions have been applied to it (referred to as the "case where consolidated tax payment ends" in this paragraph), if there is any individually attributed consolidated deficit of the domestic corporation (meaning an individually attributed consolidated deficit prescribed in Article 81-9, paragraph (6) of the Former Corporation Tax Act; the same applies in this Article and the following Article) that arose in any consolidated business year that began within ten years before the first day of the business year that includes the day following the last day of the final consolidated business year in that case of revocation of approval, that case of approval of withdrawal or that case where consolidated tax payment ends, then, with regard to the application of the provisions of Article 57, paragraph (1) of the New Corporation Tax Act, that individually attributed consolidated deficit is deemed to be a net operating loss that arose in the business year of the domestic corporation that includes the first day of the consolidated business year in which that individually attributed consolidated deficit arose (or, if the provisions of Article 29, paragraph (1) of the Supplementary Provisions have been applied, the last day of that consolidated business year).

②In the case where the acquired corporation in a qualified merger set forth in Article 57, paragraph (2) of the New Corporation Tax Act is a consolidated corporation (limited, in the case of a consolidated subsidiary corporation, to one that carries out, on the day following the last day of a consolidated business year, a qualified merger in which that consolidated subsidiary corporation is the acquired corporation), or where the other domestic corporation for which the determination of residual assets set forth in that paragraph has been made is a consolidated corporation (limited to a consolidated subsidiary corporation for which the determination of residual assets was made on the last day of a consolidated business year of that consolidated corporation), the provisions of Article 57, paragraphs (2) and (3) of the New Corporation Tax Act apply by deeming the individually attributed consolidated deficit that arose in each consolidated business year of the acquired corporation or the other domestic corporation that began within 10 years before the day of that qualified merger, or that began within 10 years before the day following the day of that determination of residual assets, to be a net operating loss that arose in a business year within the preceding 10 years prescribed in that paragraph, by deeming a consolidated tax return (meaning a consolidated tax return prescribed in Article 2, item (xxxii) of the Former Corporation Tax Act; the same applies in Article 33 and Article 35, paragraph (2) of the Supplementary Provisions) to be a Final Return that is a Blue Return, and by deeming the consolidated business year in which that individually attributed consolidated deficit arose to be a business year of the acquired corporation or the other domestic corporation.

③In the case prescribed in the preceding paragraph, when a consolidated corporation that becomes an acquired corporation involved in a qualified merger set forth in the paragraph or another domestic corporation whose residual assets have been determined shows any net operating loss that arose in each business year prior to each consolidated business year, as prescribed in the paragraph, that falls under a business year within preceding ten years as prescribed in Article 57, paragraph (2) of the New Corporation Tax Act, the provisions of the paragraph do not apply to the net operating loss.

④With regard to the application of the provisions of Article 57, paragraph (1) of the New Corporation Tax Act in each business year after the final consolidated business year in the case where a domestic corporation set forth in Article 57, paragraph (1) of the New Corporation Tax Act, after the last day of the first consolidated business year prescribed in Article 15-2, paragraph (1) of the Former Corporation Tax Act, has had the approval under Article 4-2 of the Former Corporation Tax Act revoked pursuant to the provisions of Article 4-5, paragraph (1) or (2) of the Former Corporation Tax Act (including the case where it has had the approval under Article 4-2 of the Former Corporation Tax Act revoked as governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (1) or (2) of the Supplementary Provisions), has received the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act (including the case where it has received the approval under Article 4-5, paragraph (3) of the Former Corporation Tax Act as governed by the provisions then in force pursuant to the provisions of Article 16, paragraph (3) of the Supplementary Provisions), or has had the provisions of Article 29, paragraph (1) or (2) of the Supplementary Provisions applied, the net operating losses that arose in each business year prior to that consolidated business year (including those deemed, in each such business year, to be net operating losses that arose in a business year prior to each such business year pursuant to the provisions of Article 57, paragraph (2) or (6) of the Former Corporation Tax Act) are deemed not to exist.

⑤With regard to the application of the provisions of Article 57 of the New Corporation Tax Act in the case where the provisions of paragraph (1) or the preceding paragraph apply, the phrase "of this paragraph" in paragraph (2) of that Article is deemed to be replaced with "of this paragraph or Article 20, paragraph (1) (Transitional Measures for Carryover of Losses) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020; referred to as the '2020 Income Tax Act Amendment' in this Article)", the phrase "第九項又は" (paragraph 9 or) with "第九項若しくは" (paragraph 9 or, joining a smaller group of alternatives), and the phrase "Article 58, paragraph (1) (Special Provisions for Losses in Business Years for Which No Blue Return Was Filed)" with "Article 58, paragraph (1) (Special Provisions for Losses in Business Years for Which No Blue Return Was Filed) or Article 20, paragraph (4) of the Supplementary Provisions of the 2020 Income Tax Act Amendment"; the phrase "(including those deemed to be net operating losses of the domestic corporation pursuant to the provisions of paragraph (2)" in paragraph (4) of that Article is deemed to be replaced with "(including those deemed to be net operating losses of the domestic corporation pursuant to the provisions of paragraph (2) or Article 20, paragraph (1) of the Supplementary Provisions of the 2020 Income Tax Act Amendment", and the phrase "or Article 58, paragraph (1)" with "or Article 58, paragraph (1), or Article 20, paragraph (4) of the Supplementary Provisions of the 2020 Income Tax Act Amendment"; the phrase "paragraph (2)" in paragraph (6) and paragraph (7), item (i) of that Article is deemed to be replaced with "paragraph (2) or Article 20, paragraph (1) of the Supplementary Provisions of the 2020 Income Tax Act Amendment"; the phrase "paragraph (2)" in paragraph (8), item (i) of that Article is deemed to be replaced with "paragraph (2) or Article 20, paragraph (1) of the Supplementary Provisions of the 2020 Income Tax Act Amendment", and the phrase "or Article 58, paragraph (1)" with "or Article 58, paragraph (1), or Article 20, paragraph (4) of the Supplementary Provisions of the 2020 Income Tax Act Amendment"; and the phrase "paragraph (2)" in paragraph (9) of that Article is deemed to be replaced with "paragraph (2) or Article 20, paragraph (1) of the Supplementary Provisions of the 2020 Income Tax Act Amendment".

⑥The provisions of paragraph (1) of Article 57 of the New Corporation Tax Act concerning an amount deemed to be a net operating loss of a domestic corporation pursuant to the provisions of paragraph (1), or an amount deemed to be a net operating loss of a domestic corporation pursuant to the provisions of Article 57, paragraph (2) of the New Corporation Tax Act as applied with the deeming under paragraph (2), apply only in the case where that domestic corporation has filed a Final Return for the business year that includes the day following the last day of the final consolidated business year set forth in paragraph (1), or for the business year of the merger, etc. prescribed in paragraph (2) of that Article as applied with the deeming under paragraph (2), and has subsequently filed Final Returns continuously, and where it keeps the books and documents pertaining to the business year in which the amount deemed to be a net operating loss arose as specified by Ministry of Finance Order prescribed in Article 57, paragraph (10) of the Former Corporation Tax Act.

⑦In the case where the provisions of Article 29, paragraph (1) or (2) of the Supplementary Provisions have been applied to a domestic corporation, if there is any individually attributed consolidated deficit of the domestic corporation that arose in any consolidated business year that began within nine years before the first day of the business year that includes the day following the last day of the final consolidated business year (limited to a consolidated business year that began before April 1, 2018), then, with regard to the application of the provisions of Article 57, paragraph (1) of the Corporation Tax Act prior to the amendment by Article 2 of the Act Partially Amending the Income Tax Act, etc. (Act No. 9 of 2015) (referred to as the "2015 Former Corporation Tax Act" in the provisions up to Article 22 of the Supplementary Provisions) in the case where the provisions then in force continue to govern pursuant to the provisions of Article 27, paragraph (1) of the Supplementary Provisions of that Act, that individually attributed consolidated deficit is deemed to be a net operating loss that arose in the business year of the domestic corporation that includes the last day of the consolidated business year in which that individually attributed consolidated deficit arose (or, if the provisions of Article 29, paragraph (2) of the Supplementary Provisions have been applied, the first day of that consolidated business year).

⑧With regard to the application of the provisions of Article 57, paragraph (1) of the 2015 Former Corporation Tax Act in each business year after the final consolidated business year in the case where the provisions of Article 29, paragraph (1) or (2) of the Supplementary Provisions have been applied to a domestic corporation, the net operating losses that arose in each business year prior to that consolidated business year (including those deemed, in each such business year, to be net operating losses that arose in a business year prior to each such business year pursuant to the provisions of Article 57, paragraph (2) or (6) of the 2015 Former Corporation Tax Act) are deemed not to exist.

⑨With regard to the application of the provisions of Article 57, paragraphs (2) through (4), paragraph (8) and paragraph (10) of the 2015 Former Corporation Tax Act in the case where the provisions of the preceding two paragraphs apply, an amount deemed to be a net operating loss of the domestic corporation set forth in paragraph (7) pursuant to the provisions of that paragraph is deemed to be an amount deemed to be a net operating loss of that domestic corporation pursuant to the provisions of paragraph (6) of that Article, and a net operating loss deemed not to exist pursuant to the provisions of the preceding paragraph is deemed to be a net operating loss deemed not to exist pursuant to the provisions of paragraph (9) of that Article, respectively.

⑩With regard to the application of the provisions of Article 57, paragraphs (6) through (9) of the New Corporation Tax Act to a net operating loss that arose in a business year that began before April 1, 2018, the phrase "of paragraph (1)" in paragraph (6) of that Article is deemed to be replaced with "of Article 57, paragraph (1) (Carryover of Losses in a Business Year When a Blue Return Has Been Filed) of the Corporation Tax Act prior to the amendment by Article 2 of the Act Partially Amending the Income Tax Act, etc. (Act No. 9 of 2015) (referred to as the '2015 Former Corporation Tax Act' in this Article) in the case where the provisions then in force continue to govern pursuant to the provisions of Article 27, paragraph (1) (Transitional Measures for Carryover of Losses in Business Years When a Blue Return Has Been Filed, etc.) of the Supplementary Provisions of that Act", and the phrase "paragraph (2)" with "paragraph (2) or (6) of that Article or Article 20, paragraph (7) (Transitional Measures for Carryover of Losses) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 8 of 2020; referred to as the '2020 Income Tax Act Amendment' in this Article)"; the phrase ", paragraph (2)" in paragraph (7) of that Article is deemed to be replaced with ", Article 57, paragraph (2) of the 2015 Former Corporation Tax Act"; the phrase "business year within preceding ten years" in item (i) of that paragraph is deemed to be replaced with "business year within preceding nine years prescribed in Article 57, paragraph (2) of the 2015 Former Corporation Tax Act", and the phrase "paragraph (2)" with "that paragraph or paragraph (6) of that Article or Article 20, paragraph (7) of the Supplementary Provisions of the 2020 Income Tax Act Amendment"; the phrase "of paragraph (1) in each business year" in paragraph (8) of that Article is deemed to be replaced with "of Article 57, paragraph (1) of the 2015 Former Corporation Tax Act in each business year"; the phrase "business years within ten years before group tax sharing" in item (i) of that paragraph is deemed to be replaced with "business years within nine years before group tax sharing", the phrase "within ten years" with "within nine years", the phrase "paragraph (2)" with "Article 57, paragraph (2) or (6) of the 2015 Former Corporation Tax Act or Article 20, paragraph (7) of the Supplementary Provisions of the 2020 Income Tax Act Amendment", the phrase ", paragraph (1)" with ", Article 57, paragraph (1) of the 2015 Former Corporation Tax Act", the phrase "paragraphs (4) through (6)" with "the provisions of paragraph (4), (5) or (9) of that Article, paragraph (6)", and the phrase "or Article 58, paragraph (1)" with "or the provisions of Article 20, paragraph (8) of the Supplementary Provisions of the 2020 Income Tax Act Amendment"; the phrase "business years within ten years before group tax sharing" in item (ii) of that paragraph is deemed to be replaced with "business years within nine years before group tax sharing"; and the phrase "paragraph (1)" in paragraph (9) of that Article is deemed to be replaced with "Article 57, paragraph (1) of the 2015 Former Corporation Tax Act", and the phrase "paragraph (2)" with "paragraph (2) or (6) of that Article or Article 20, paragraph (7) of the Supplementary Provisions of the 2020 Income Tax Act Amendment".

⑪The provisions of Article 57, paragraph (6), paragraph (7) (limited to the part pertaining to item (i)) and paragraph (8) of the New Corporation Tax Act do not apply to the net operating loss of a group tax sharing corporation that is deemed to have received the approval under Article 64-9, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 29, paragraph (1) of the Supplementary Provisions.

⑫The provisions of Article 57, paragraphs (6) through (8) of the New Corporation Tax Act apply by deeming a domestic corporation that is deemed to fall under a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions to fall under a corporation listed in any of the items of Article 64-11, paragraph (1) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, and by deeming a domestic corporation that is deemed not to fall under a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 30, paragraph (3) or (5) of the Supplementary Provisions not to fall under a corporation listed in Article 64-11, paragraph (1), item (ii) or any of the items of Article 64-12, paragraph (1) of the New Corporation Tax Act, respectively.

⑬With regard to the application of the provisions of Article 57 of the New Corporation Tax Act to a group tax sharing parent corporation and the other group tax sharing corporations in the case where the group tax sharing parent corporation is one deemed to have received the approval under Article 64-9, paragraph (1) of the New Corporation Tax Act pursuant to the provisions of Article 29, paragraph (1) of the Supplementary Provisions, and a fact listed in Article 57, paragraph (11), item (ii), (a) through (d) of the Former Corporation Tax Act occurred with respect to that group tax sharing parent corporation in a business year that began before April 1, 2022, the phrase "with respect to a domestic corporation" in paragraph (11), item (ii) of that Article is deemed to be replaced with "with respect to a domestic corporation (including the group tax sharing parent corporation related to that domestic corporation)", and the phrase "of that domestic corporation" with "of the domestic corporation with respect to which that fact occurred".

⑭Necessary matters concerning the application of the provisions of the preceding paragraphs are specified by Cabinet Order.