This Act comes into effect on April 1, 2023; 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 the provisions of Article 2 (limited to the amending provisions listed in Article 1, item (iv), (a) of the Supplementary Provisions) (hereinafter referred to as the "Corporation Tax Act as Amended for 2024") (limited to the part concerning corporation tax on the international minimum tax amount prescribed in Article 82-2, paragraph (1) of the Corporation Tax Act as Amended for 2024 for each covered fiscal year) apply to corporation tax on the international minimum tax amount prescribed in that paragraph of a domestic corporation for a covered fiscal year beginning on or after April 1, 2024.

①The provisions of Article 61 of the Corporation Tax Act as amended by the provisions of Article 2 (hereinafter referred to as the "New Corporation Tax Act") apply to corporation tax on income for a business year of a corporation (including an association or foundation without juridical personality; hereinafter the same applies in this Article and Article 15 of the Supplementary Provisions) beginning on or after the Effective Date, and with regard to corporation tax on income for a business year of a corporation that began before the Effective Date, except in the cases prescribed in the following paragraph and paragraphs (4) through (6), the provisions then in force continue to govern.

②In the case where, at the end of the business year of the amendment (meaning the business year that includes the Effective Date; hereinafter the same applies in this paragraph and the following paragraph), a corporation holds crypto-assets prescribed in Article 61, paragraph (1) of the Corporation Tax Act that were issued by that corporation (for a business year of the amendment beginning on the Effective Date, limited to crypto-assets (meaning crypto-assets prescribed in Article 61, paragraph (1) of the Corporation Tax Act; hereinafter the same applies in this Article) that do not fall under specified self-issued crypto-assets prescribed in Article 61, paragraph (2) of the New Corporation Tax Act (hereinafter referred to as "specified self-issued crypto-assets" in this Article)), if all of those crypto-assets (excluding those acquired from other persons) fall, at that time, under those specified by Cabinet Order as being subject to restrictions on transfer or other conditions, the corporation may, for each business year on or before the business year of the amendment, apply the provisions of Article 61 of the New Corporation Tax Act by deeming crypto-assets of the same type as those crypto-assets (excluding those acquired from other persons) to fall under specified self-issued crypto-assets.

③With regard to the application of the provisions of Article 61 of the New Corporation Tax Act in each business year after the business year of the amendment to crypto-assets deemed to fall under specified self-issued crypto-assets pursuant to the provisions of the preceding paragraph, those crypto-assets (limited to crypto-assets that were issued by the corporation referred to in that paragraph and that it has held continuously since the end of the business year of the amendment, and that have continuously fallen, since that time, under those specified by Cabinet Order as prescribed in that paragraph) are deemed to fall under specified self-issued crypto-assets.

④In the case where, among the crypto-asset margin transactions prescribed in Article 61, paragraph (8) of the New Corporation Tax Act (excluding those falling under the crypto-asset margin transactions prescribed in Article 61, paragraph (7) of the Corporation Tax Act prior to the amendment by the provisions of Article 2 (hereinafter referred to as the "Former Corporation Tax Act"); hereinafter referred to as "new crypto asset margin transactions" in this Article) conducted by a corporation in a business year that began before the Effective Date (hereinafter referred to as a "transitional business year" in this Article), there are any that remain unsettled at the end of a transitional business year ending on or after the day on which they were conducted, if, in the finalized settlement of accounts for that transitional business year (in the case of filing an interim return stating the matters listed in the items of Article 72, paragraph (1) or the items of Article 144-4, paragraph (1) of the Corporation Tax Act for the period prescribed in Article 72, paragraph (1) or Article 144-4, paragraph (1) of that Act (for a group tax sharing subsidiary corporation, the period prescribed in Article 72, paragraph (5), item (i) of that Act), the settlement of accounts for that period; the same applies in paragraph (6)), the corporation has entered in its accounts, as profit or loss, the deemed settlement profit or loss prescribed in Article 61, paragraph (8) of the New Corporation Tax Act for all of the new crypto asset margin transactions that remain unsettled at the end of that transitional business year, the corporation may apply the provisions of that paragraph for that transitional business year.

⑤In the case where, among the new crypto asset margin transactions conducted by a corporation in a transitional business year, there are any whose contracts the corporation has transferred to a succeeding corporation in a company split or a corporation receiving a capital contribution in kind as a result of a qualified company split, etc. prescribed in Article 61, paragraph (9) of the New Corporation Tax Act carried out on or after the day on which they were conducted, if the corporation has treated the amount equivalent to the deemed settlement profit or loss prescribed in that paragraph for all of the new crypto asset margin transactions pertaining to the contracts transferred as a result of that qualified company split, etc. as an amount of proceeds or an amount of loss, the corporation may apply the provisions of that paragraph to that qualified company split, etc.

⑥In the case where a corporation has acquired crypto-assets based on a contract pertaining to new crypto asset margin transactions in a transitional business year, if, for all of the crypto-assets acquired in that transitional business year based on contracts pertaining to new crypto asset margin transactions, the corporation has entered in its accounts as profit or loss, in the finalized settlement of accounts for that transitional business year, the difference between the value of the crypto-assets as of the time of the acquisition and the amount that the corporation paid as the consideration for the acquisition of the crypto-assets based on a contract pertaining to new crypto asset margin transactions that had caused the acquisition, the corporation may apply the provisions of Article 61, paragraph (10) of the New Corporation Tax Act for that transitional business year.

⑦The application of the provisions of Article 61 of the New Corporation Tax Act in the case where crypto-assets deemed to fall under specified self-issued crypto-assets pursuant to the provisions of paragraph (2) have been transferred as a result of a qualified merger or qualified company split, and other necessary matters concerning the application of the provisions of that paragraph through the preceding paragraph, are specified by Cabinet Order.

The provisions of Article 74, paragraph (2) and Article 75-2, paragraph (11), item (i) of the New Corporation Tax Act apply to corporation tax on income for the business year that includes the date of determination of residual assets of a domestic corporation whose residual assets are determined on or after the Effective Date (including a business year that includes the date of determination of residual assets of a domestic corporation whose residual assets were determined before the Effective Date, for which the due date for filing prescribed in Article 74, paragraph (1) of the Former Corporation Tax Act, as applied with the replacement of terms pursuant to paragraph (2) of that Article, for the return under paragraph (1) of that Article for that business year arrives on or after the Effective Date (hereinafter referred to as a "transitional business year" in this Article)), and with regard to corporation tax on income for the business year that includes the date of determination of residual assets of a domestic corporation whose residual assets were determined before the Effective Date (excluding a transitional business year), the provisions then in force continue to govern.

①In the case where a constituent entity (meaning a constituent entity prescribed in Article 82, item (xiii) of the Corporation Tax Act as Amended for 2024; hereinafter the same applies in this Article and Article 16, paragraph (3) of the Supplementary Provisions) that belongs to the specified multinational enterprise group, etc. (meaning a specified multinational enterprise group, etc. prescribed in Article 82, item (iv) of the Corporation Tax Act as Amended for 2024; hereinafter the same applies through Article 18-2 of the Supplementary Provisions) to which a domestic corporation that is a constituent entity belongs (excluding an excluded constituent entity (meaning a stateless constituent entity prescribed in Article 82, item (xviii) of the Corporation Tax Act as Amended for 2024 or any other entity specified by Cabinet Order; hereinafter the same applies in this paragraph); hereinafter the same applies in this paragraph) satisfies any of the following requirements in a covered fiscal year beginning during the period from April 1, 2024 to December 31, 2027 (limited to one ending by June 30, 2029), the amounts prescribed in Article 82-3, paragraph (2), items (i) through (iii) of the Corporation Tax Act for that covered fiscal year in the country of location (meaning the country of location prescribed in Article 82, item (vii) of the Corporation Tax Act as Amended for 2024; hereinafter the same applies in this Article) of that constituent entity for that covered fiscal year are to be zero.

②The provisions of the preceding paragraph apply only where all of the following requirements are satisfied:

③In the case where a jointly controlled entity, etc. (meaning a jointly controlled entity, etc. prescribed in Article 82, item (xv) of the Corporation Tax Act as Amended for 2024; hereinafter the same applies in this Article) of the specified multinational enterprise group, etc. to which a domestic corporation that is a constituent entity belongs (excluding an excluded joint venture (meaning a stateless jointly controlled entity prescribed in Article 82, item (xxii) of the Corporation Tax Act as Amended for 2024 or any other entity specified by Cabinet Order); hereinafter the same applies in this paragraph) satisfies any of the following requirements in a covered fiscal year beginning during the period from April 1, 2024 to December 31, 2027 (limited to one ending by June 30, 2029), the amounts prescribed in Article 82-3, paragraph (4), items (i) through (iii) of the Corporation Tax Act for that covered fiscal year in the country of location of that jointly controlled entity, etc. for that covered fiscal year are to be zero.

④The provisions of the preceding paragraph apply only where all of the following requirements are satisfied:

⑤With regard to the application of the provisions of Article 82-3, paragraph (2), item (i), (a), (2), (i) and paragraph (4), item (i), (a), (2), (i) of the Corporation Tax Act in calculating the current jurisdictional international minimum tax amount listed in Article 82-3, paragraph (2), item (i), (a) and paragraph (4), item (i), (a) of that Act of a specified multinational enterprise group, etc. for a covered fiscal year beginning during the period from April 1, 2024 to December 31, 2032 of a domestic corporation that is a constituent entity belonging to that specified multinational enterprise group, etc., the phrase "5 percent" in these provisions is deemed to be replaced with "9.8 percent" for a covered fiscal year of that domestic corporation beginning during the period from April 1, 2024 to December 31, 2024, with "9.6 percent" for a covered fiscal year of that domestic corporation beginning during the period from January 1, 2025 to December 31, 2025, with "9.4 percent" for a covered fiscal year of that domestic corporation beginning during the period from January 1, 2026 to December 31, 2026, with "9.2 percent" for a covered fiscal year of that domestic corporation beginning during the period from January 1, 2027 to December 31, 2027, with "9 percent" for a covered fiscal year of that domestic corporation beginning during the period from January 1, 2028 to December 31, 2028, with "8.2 percent" for a covered fiscal year of that domestic corporation beginning during the period from January 1, 2029 to December 31, 2029, with "7.4 percent" for a covered fiscal year of that domestic corporation beginning during the period from January 1, 2030 to December 31, 2030, with "6.6 percent" for a covered fiscal year of that domestic corporation beginning during the period from January 1, 2031 to December 31, 2031, and with "5.8 percent" for a covered fiscal year of that domestic corporation beginning during the period from January 1, 2032 to December 31, 2032.

⑥The provisions of the preceding paragraph apply mutatis mutandis to the application of the provisions of Article 82-3, paragraph (2), item (i), (a), (2), (ii) and paragraph (4), item (i), (a), (2), (ii) of the Corporation Tax Act in the case prescribed in that paragraph. In this case, the phrase "9.8 percent" in the preceding paragraph is deemed to be replaced with "7.8 percent", "9.6 percent" with "7.6 percent", "9.4 percent" with "7.4 percent", "9.2 percent" with "7.2 percent", "9 percent"" with "7 percent"", "8.2 percent" with "6.6 percent", "7.4 percent" with "6.2 percent", "6.6 percent" with "5.8 percent", and "5.8 percent" with "5.4 percent".

⑦Special provisions for the requirements listed in the items of paragraph (1) or the items of paragraph (3) in the case where a constituent entity belonging to the specified multinational enterprise group, etc. prescribed in paragraph (1) is an investment entity, etc. (meaning an investment entity, etc. prescribed in Article 82, item (xvi) of the Corporation Tax Act as Amended for 2024; hereinafter the same applies in this paragraph) or where a jointly controlled entity, etc. of the specified multinational enterprise group, etc. prescribed in paragraph (3) is an investment entity, etc., and other necessary matters concerning the application of the provisions of the preceding paragraphs are specified by Cabinet Order.

In the case where the due date for filing a return under Article 82-6, paragraph (1) of the Corporation Tax Act by a domestic corporation belonging to a specified multinational enterprise group, etc. is before June 30, 2026, the due date for filing that return is to be that date, notwithstanding the provisions of that paragraph.

The provisions of Article 128 of the New Corporation Tax Act (including as applied mutatis mutandis pursuant to Article 146, paragraph (1) of the New Corporation Tax Act; hereinafter the same applies in this Article) apply to the submission of a report under Article 128 of the New Corporation Tax Act in the case where a corporation wishes to stop filing a return listed in the items of Article 121, paragraph (1) of the Corporation Tax Act via a Blue Return for a business year beginning on or after January 1, 2026, and with regard to the submission of a report under Article 128 of the Former Corporation Tax Act (including as applied mutatis mutandis pursuant to Article 146, paragraph (1) of the Corporation Tax Act) in the case where a corporation wishes to stop filing a return listed in the items of that paragraph via a Blue Return for a business year that began before that date, the provisions then in force continue to govern.

①The provisions of Article 150-3 of the Corporation Tax Act as Amended for 2024 apply to the specified multinational enterprise group, etc. report items, etc. prescribed in paragraph (1) of that Article for a covered fiscal year beginning on or after April 1, 2024.

②With regard to the application of the provisions of Article 150-3, paragraph (1) of the Corporation Tax Act in the case where the application of the provisions of Article 14, paragraph (1) or (3) of the Supplementary Provisions is sought, the phrase "(International Minimum Tax Residual Amount)" in item (ii) of that paragraph is deemed to be replaced with "(International Minimum Tax Residual Amount), the provisions of Article 14, paragraph (1) or (3) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 3 of 2023) (Transitional Measures for Calculation of the International Minimum Tax Amount)".

③In the case where the deadline for the provision of the specified multinational enterprise group, etc. report items, etc. prescribed in Article 150-3, paragraph (1) of the Corporation Tax Act under that paragraph with regard to a domestic corporation that is a constituent entity belonging to a specified multinational enterprise group, etc., the deadline for the provision of the matters specified by Ministry of Finance Order prescribed in paragraph (2) of that Article under that paragraph with regard to that domestic corporation, the deadline for the provision of the notification items on the ultimate parent company, etc. prescribed in paragraph (4) of that Article under that paragraph with regard to that domestic corporation, or the deadline for the provision of the matters specified by Ministry of Finance Order prescribed in paragraph (5) of that Article under that paragraph with regard to that domestic corporation is before June 30, 2026, those deadlines for provision are to be that date, notwithstanding those provisions.

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.