一all of the following requirements are satisfied:

イthe revenue for Japan that was provided, in the country-by-country report (meaning the country-by-country report prescribed in Article 66-4-4, paragraph (1) of the Act on Special Measures Concerning Taxation, limited to one prepared on the basis of the consolidated financial statements, etc. (meaning the consolidated financial statements, etc. prescribed in Article 82, item (i) of the Corporation Tax Act as Amended for 2026; hereinafter the same applies in this Article); hereinafter the same applies in this paragraph) for that covered fiscal year or as information equivalent thereto, to the competent district director prescribed in Article 66-4-4, paragraph (1) or (2) of the Act on Special Measures Concerning Taxation or to the authority enforcing the laws and regulations on taxes of a country or region other than Japan (hereinafter referred to as the "competent district director, etc." in this paragraph) (where, among the constituent entities (limited to those whose country of location is Japan, and excluding excluded constituent entities; the same applies in this (a)) belonging 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 2026; hereinafter the same applies in this Article) of that domestic corporation, there is a constituent entity specified by Ministry of Finance Order as one whose revenue is not included in that revenue because its information is not included in the country-by-country report, the amount obtained by adding the amount specified by Ministry of Finance Order as the revenue for that constituent entity) (where that country-by-country report or information equivalent thereto is not provided, that revenue for Japan on the assumption that it were provided as that country-by-country report or information equivalent thereto to the country of location of the ultimate parent company, etc. (meaning the ultimate parent company, etc. prescribed in Article 82, item (x) of the Corporation Tax Act as Amended for 2026; hereinafter the same applies in this paragraph)) is less than the amount obtained by converting 10 million euros into the amount in Japanese yen as specified by Ministry of Finance Order;

ロthe amount of profit before tax for Japan that was provided to the competent district director, etc. in the country-by-country report for that covered fiscal year or as information equivalent thereto (where, in the calculation of that amount of profit before tax, there is an amount specified by Cabinet Order as an amount of loss not included in the calculation of the amount of individual computed income, etc. prescribed in Article 82, item (xxvi) of the Corporation Tax Act as Amended for 2026, the amount calculated as not including that amount; referred to as the "amount of adjusted profit before tax" in this (b) and in (b) of the following item) (where that country-by-country report or information equivalent thereto is not provided, the amount of adjusted profit before tax for Japan on the assumption that it were provided as that country-by-country report or information equivalent thereto to the country of location of the ultimate parent company, etc.) is less than the amount obtained by converting 1 million euros into the amount in Japanese yen as specified by Ministry of Finance Order;

二the ratio of the amount listed in (a) to the amount listed in (b) (limited to an amount exceeding zero) is 17 percent or more:

イthe sum of the amount of corporation tax and other amounts specified by Ministry of Finance Order that are stated in the consolidated financial statements, etc. of all constituent entities (excluding stateless constituent entities prescribed in Article 82, item (xviii) of the Corporation Tax Act as Amended for 2026 and excluded constituent entities) for which the country or region where the business referred to in Article 66-4-4, paragraph (1) of the Act on Special Measures Concerning Taxation is conducted is Japan for that covered fiscal year (where those amounts include the amount of taxes other than the covered taxes prescribed in Article 82, item (xxix) of the Corporation Tax Act as Amended for 2026, or include an amount specified by Ministry of Finance Order as an amount involving uncertainty, excluding these amounts);

ロthe amount of adjusted profit before tax for Japan that was provided to the competent district director, etc. in the country-by-country report for that covered fiscal year or as information equivalent thereto (where that country-by-country report or information equivalent thereto is not provided, the amount of adjusted profit before tax for Japan on the assumption that it were provided as that country-by-country report or information equivalent thereto to the country of location of the ultimate parent company, etc.);

三the amount listed in (b) of the preceding item is the amount listed in Article 82-19, paragraph (2), item (i), (a), (2) of the Corporation Tax Act as Amended for 2026 as calculated without applying the provisions of paragraph (4) of that Article pertaining to that domestic corporation for that covered fiscal year (limited to the amount pertaining to constituent entities (excluding excluded constituent entities) for which the country or region where the business referred to in Article 66-4-4, paragraph (1) of the Act on Special Measures Concerning Taxation is conducted, in the country-by-country report for that covered fiscal year or information equivalent thereto, and the country of location are both Japan) or less.

一the group domestic minimum tax report items, etc. prescribed in Article 150-3, paragraph (4) of the Corporation Tax Act as Amended for 2026 for each covered fiscal year of the specified multinational enterprise group, etc. of the domestic corporation referred to in the preceding paragraph (limited to those that include a statement to the effect that the application of the provisions of the preceding paragraph is sought with regard to that domestic corporation; hereinafter the same applies in this item) have been provided, or information equivalent to those group domestic minimum tax report items, etc. has been provided to the authority enforcing the laws and regulations on taxes of a country or region other than Japan (limited to the case where the provisions of paragraph (6) of that Article apply);

二in each covered fiscal year that began before the first day of the covered fiscal year for which the application of the provisions of the preceding paragraph is sought (limited to the covered fiscal year in which the specified multinational enterprise group, etc. referred to in the preceding item came to fall under a specified multinational enterprise group, etc. in Japan on or after April 1, 2024, and the covered fiscal year in which the specified multinational enterprise group, etc. referred to in the preceding item came to fall under a specified multinational enterprise group, etc., on or after the date on which they came into effect, in a country or region where provisions of laws and regulations on taxes of a country or region other than Japan equivalent to the provisions of Article 14, paragraph (1) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 3 of 2023) are in effect), the international minimum tax amount prescribed in Article 82-3, paragraph (1) of the Corporation Tax Act or its equivalent in a foreign country has been calculated with regard to Japan by applying the provisions of paragraph (1) of that Article (including the provisions of laws and regulations on taxes of a country or region other than Japan equivalent to the provisions of that paragraph), or the amount prescribed in Article 82-19, paragraph (1), item (i) or Article 145-6, paragraph (1), item (i) of that Act has been calculated by applying the provisions of the preceding paragraph (including as applied mutatis mutandis pursuant to paragraph (5)).

一all of the following requirements are satisfied:

イthe sum of the amounts specified by Ministry of Finance Order as revenue stated in the consolidated financial statements, etc. of that domestic corporation and of other jointly controlled entities, etc. related to that domestic corporation (limited to those whose country of location is Japan, and excluding excluded joint ventures; hereinafter the same applies in this paragraph and item (ii) of the following paragraph) for that covered fiscal year is less than the amount obtained by converting 10 million euros into the amount in Japanese yen as specified by Ministry of Finance Order;

ロthe amount obtained by deducting the sum of the amounts specified by Ministry of Finance Order as the amount of net loss before tax stated in those consolidated financial statements, etc. from the sum of the amounts specified by Ministry of Finance Order as the amount of net profit before tax stated in the consolidated financial statements, etc. of that domestic corporation and of other jointly controlled entities, etc. related to that domestic corporation for that covered fiscal year (where, in the calculation of that amount, there is an amount specified by Cabinet Order as an amount of loss not included in the calculation of the amount of individual computed income, etc. prescribed in Article 82, item (xxvi) of the Corporation Tax Act as Amended for 2026, the amount calculated as not including that amount; referred to as the "amount of adjusted profit before tax" in (b) of the following item) is less than the amount obtained by converting 1 million euros into the amount in Japanese yen as specified by Ministry of Finance Order;

二the ratio of the amount listed in (a) to the amount listed in (b) (limited to an amount exceeding zero) is 17 percent or more:

イthe sum of the amount of corporation tax and other amounts specified by Ministry of Finance Order in the consolidated financial statements, etc. of that domestic corporation and of other jointly controlled entities, etc. related to that domestic corporation for that covered fiscal year (where those amounts include the amount of taxes other than the covered taxes prescribed in Article 82, item (xxix) of the Corporation Tax Act as Amended for 2026, or include an amount specified by Ministry of Finance Order as an amount involving uncertainty, excluding these amounts);

ロthe amount of adjusted profit before tax of that domestic corporation and of other jointly controlled entities, etc. related to that domestic corporation for that covered fiscal year;

三the amount listed in (b) of the preceding item is the amount listed in Article 82-19, paragraph (5), item (i), (a), (2) of the Corporation Tax Act as Amended for 2026 as calculated without applying the provisions of paragraph (7) of that Article pertaining to that domestic corporation for that covered fiscal year or less.

一the group domestic minimum tax report items, etc. prescribed in Article 150-3, paragraph (4) of the Corporation Tax Act as Amended for 2026 for each covered fiscal year of the specified multinational enterprise group, etc. of the domestic corporation referred to in the preceding paragraph (limited to those that include a statement to the effect that the application of the provisions of the preceding paragraph is sought with regard to that domestic corporation; hereinafter the same applies in this item) have been provided, or information equivalent to those group domestic minimum tax report items, etc. has been provided to the authority enforcing the laws and regulations on taxes of a country or region other than Japan (limited to the case where the provisions of paragraph (6) of that Article apply);

二in each covered fiscal year that began before the first day of the covered fiscal year for which the application of the provisions of the preceding paragraph is sought (limited to the covered fiscal year in which the specified multinational enterprise group, etc. referred to in the preceding item came to fall under a specified multinational enterprise group, etc. in Japan on or after April 1, 2024, and the covered fiscal year in which the specified multinational enterprise group, etc. referred to in the preceding item came to fall under a specified multinational enterprise group, etc., on or after the date on which they came into effect, in a country or region where provisions of laws and regulations on taxes of a country or region other than Japan equivalent to the provisions of Article 14, paragraph (3) of the Supplementary Provisions of the Act Partially Amending the Income Tax Act, etc. (Act No. 3 of 2023) are in effect), the international minimum tax amount prescribed in Article 82-3, paragraph (1) of the Corporation Tax Act or its equivalent in a foreign country has been calculated in Japan with regard to the domestic corporation referred to in the preceding paragraph or other jointly controlled entities, etc. related to that domestic corporation by applying the provisions of paragraph (3) of that Article (including the provisions of laws and regulations on taxes of a country or region other than Japan equivalent to the provisions of that paragraph), or the amount prescribed in Article 82-19, paragraph (1), item (ii) or Article 145-6, paragraph (1), item (ii) of that Act has been calculated by applying the provisions of the preceding paragraph (including as applied mutatis mutandis pursuant to paragraph (6)).