Article 225Carry-Over, Credit-Eligible Foreign Income Taxes, etc.

①The amount specified by Cabinet Order as the portion to be carried over to that year prescribed in Article 95, paragraph (3) (Foreign Tax Credit) of the Act is the amount equivalent to the sum of the amounts exceeding the credit limit that would be applied to the unused portion within the maximum creditable amount for national tax of that year (meaning the unused portion within the maximum creditable amount for national tax prescribed in paragraph (4) of the preceding Article; the same applies hereinafter in this Article) if the amounts exceeding the credit limit for each year within the previous three years (meaning the amount exceeding the credit limit prescribed in paragraph (6) of the preceding Article; the same applies hereinafter in this Article) were applied to that unused portion in order from the oldest year.

②The provisions of paragraph (2) of the preceding Article apply mutatis mutandis to the case referred to in the preceding paragraph. In this case, the phrase "the unused portion within the maximum creditable amount for national tax and the unused portion within the maximum creditable amount for local taxes" in paragraph (2) of that Article is deemed to be replaced with "the amount exceeding the credit limit".

③With regard to the application of the provisions of paragraph (1) and paragraph (1) of the preceding Article for each year after the year in which Article 95, paragraph (3) of the Act can be applied, the amount exceeding the credit limit that is to be applied, under the provisions of paragraph (1), to the unused portion within the maximum creditable amount for national tax of the year in which that application can be received, and that unused portion within the maximum creditable amount for national tax equivalent to it, are deemed not to exist.

④With regard to the application of the provisions of paragraph (1) and paragraph (1) of the preceding Article for each year after the year in which Article 7-19, paragraph (2) (Credit of Foreign Income Tax Amount against Prefectural Inhabitant Tax) of the Order for Enforcement of the Local Tax Act can be applied (excluding a year in which Article 48-9-2, paragraph (2) (Credit of Foreign Income Tax Amount against Municipal Inhabitant Tax) of that Order can also be applied) or the year in which Article 48-9-2, paragraph (2) of that Order can be applied, the amount exceeding the credit limit equivalent to the amount deemed to be the amount of income tax, etc. of a foreign country imposed in the year in which that application can be received under the provisions of Article 7-19, paragraph (2) or Article 48-9-2, paragraph (2) of that Order (excluding, where part of that amount exceeding the credit limit is to be applied under the provisions of paragraph (1) to the unused portion within the maximum creditable amount for national tax of the year in which that application can be received, the portion to be so applied), and the unused portion within the maximum creditable amount for local taxes prescribed in paragraph (5) of the preceding Article of the year in which that application can be received that is equivalent to it, are respectively deemed not to exist.