Article 225-2Income to Be Attributed to a Foreign Office or Similar Establishment

①The thing specified by Cabinet Order, such as a thing equivalent to a permanent establishment located outside Japan, prescribed in Article 95, paragraph (4), item (i) (Foreign Tax Credit) of the Act is to be, for a treaty partner state, etc. with which Japan has concluded a tax treaty (meaning a treaty prescribed in the proviso to Article 2, paragraph (1), item (viii)-4 (Definitions) of the Act, limited to one that provides that tax may be imposed on income attributable to a thing equivalent to a permanent establishment located within a Contracting State or Contracting Party to that treaty other than Japan (hereinafter in this paragraph referred to as a "treaty partner state, etc."); the same applies hereinafter in this paragraph), the thing equivalent to a permanent establishment provided for in that tax treaty that is located within the treaty partner state, etc. of that tax treaty; for a foreign country (meaning a foreign country prescribed in Article 2, item (iii) (Definitions) of the Act on Exemption, etc. of Income Tax, etc. on Income of Foreign Residents, etc. Based on the Principle of Reciprocity, and excluding that foreign country where it does not fall under any of the items of Article 5 (Principle of Reciprocity) of that Act; the same applies hereinafter in this paragraph), the thing equivalent to a domestic office, etc. prescribed in Article 2, item (vi) of the Act on Exemption, etc. of Income Tax, etc. on Income of Foreign Residents, etc. Based on the Principle of Reciprocity that is located in that foreign country; and, for any other country or region, the thing equivalent to a permanent establishment located in that country or region.

②The things specified by Cabinet Order as a place of business or other thing equivalent thereto prescribed in Article 95, paragraph (4), item (i) of the Act are the following: