Where, in any year within the seven years starting from the year following the year in which the application of Article 95, paragraphs (1) through (3) (Foreign Tax Credit) of the Act was received with respect to the amount of foreign income tax that a Resident became liable to pay, the amount of that foreign income tax is reduced, for the year in which the date on which that amount is to be reduced falls for that Resident (hereinafter in this Article referred to as the "year of the reduction"), an amount equivalent to the reduced amount of credit-eligible foreign income tax is to be deducted from the amount of credit-eligible foreign income tax that that Resident is to pay in the year of the reduction (referred to in paragraph (3) as the "credit-eligible foreign income tax to be paid"), and the provisions of Article 95, paragraphs (1) through (3) of the Act apply to the amount after that deduction.
居住者が納付することとなつた外国所得税の額につき法第九十五条第一項から第三項まで(外国税額控除)の規定の適用を受けた年の翌年以後七年内の各年において当該外国所得税の額が減額された場合には、当該居住者のその減額されることとなつた日の属する年(以下この条において「減額に係る年」という。)については、当該減額に係る年において当該居住者が納付することとなる控除対象外国所得税の額(第三項において「納付控除対象外国所得税額」という。)から減額控除対象外国所得税額に相当する金額を控除し、その控除後の金額につき法第九十五条第一項から第三項までの規定を適用する。
The reduced amount of credit-eligible foreign income tax prescribed in the preceding paragraph means, of the amount by which the amount of foreign income tax was reduced in the year of the reduction of a Resident, the amount equivalent to the remainder obtained by deducting the amount listed in item (ii) from the amount listed in item (i):
the portion of the amount of that foreign income tax that was treated as the amount of credit-eligible foreign income tax in the year in which the Resident received the application of Article 95, paragraphs (1) through (3) of the Act;
当該外国所得税の額のうち居住者の法第九十五条第一項から第三項までの規定の適用を受けた年において控除対象外国所得税の額とされた部分の金額
the portion of the amount of that foreign income tax after that reduction that would be treated as the amount of credit-eligible foreign income tax if, in the year in which that Resident received the application of Article 95, paragraphs (1) through (3) of the Act, paragraph (1) of that Article had been applied to it.
当該減額がされた後の当該外国所得税の額につき当該居住者の法第九十五条第一項から第三項までの規定の適用を受けた年において同条第一項の規定を適用したならば控除対象外国所得税の額とされる部分の金額
In the case referred to in paragraph (1), where there is no credit-eligible foreign income tax to be paid for the year of the reduction, or where that credit-eligible foreign income tax to be paid is less than the reduced amount of credit-eligible foreign income tax prescribed in the preceding paragraph (hereinafter in this paragraph referred to as the "reduced amount of credit-eligible foreign income tax"), the full amount of that reduced amount of credit-eligible foreign income tax, or the amount equivalent to the portion of that reduced amount of credit-eligible foreign income tax exceeding that credit-eligible foreign income tax to be paid, respectively, is to be deducted from the amount exceeding the credit limit prescribed in Article 224, paragraph (6) (Maximum Carry-Over Credit, etc.) for each year within the three years up to and including the year preceding the year of the reduction (excluding the amount of the portion deemed not to exist in each year up to and including the year preceding the year of the reduction under paragraph (3) of that Article or Article 225, paragraph (3) or (4) (Carry-Over, Credit-Eligible Foreign Income Taxes, etc.); hereinafter in this paragraph referred to as the "amount exceeding the credit limit"), and the provisions of Article 95, paragraph (3) of the Act apply to the amount after that deduction. In this case, where there is an amount exceeding the credit limit for two or more years, the deduction is made first from the amount exceeding the credit limit for the oldest year, and where there remains an amount that cannot be fully deducted, the deduction is made successively from the amount exceeding the credit limit for newer years.
第一項の場合において、減額に係る年の納付控除対象外国所得税額がないとき、又は当該納付控除対象外国所得税額が前項に規定する減額控除対象外国所得税額(以下この項において「減額控除対象外国所得税額」という。)に満たないときは、減額に係る年の前年以前三年内の各年の第二百二十四条第六項(繰越控除限度額等)に規定する控除限度超過額(同条第三項又は第二百二十五条第三項若しくは第四項(繰越控除対象外国所得税額等)の規定により減額に係る年の前年以前の各年においてないものとみなされた部分の金額を除く。以下この項において「控除限度超過額」という。)から、それぞれ当該減額控除対象外国所得税額の全額又は当該減額控除対象外国所得税額のうち当該納付控除対象外国所得税額を超える部分の金額に相当する金額を控除し、その控除後の金額につき法第九十五条第三項の規定を適用する。この場合において、二以上の年につき控除限度超過額があるときは、まず最も古い年の控除限度超過額から当該控除を行い、なお控除しきれない金額があるときは順次新しい年の控除限度超過額から当該控除を行う。
Read this with the articles around it
foreign income taxmachine translation
「外国所得税」
In the chapter on the foreign tax credit, a tax imposed under foreign law by a foreign country or one of its local governments with an individual's income as its tax base.
Short name set inArticle 221, paragraph (1)· applies only in this chapter
amount of credit-eligible foreign income taxmachine translation
「控除対象外国所得税の額」
In Articles 224 and 226, the credit-eligible foreign income tax as defined in Article 95, paragraph (1) of the Income Tax Act: the foreign income tax a resident has to pay that can be credited against Japanese income tax, leaving out tax on income from transactions not regarded as ordinary and other foreign income tax a Cabinet Order (政令) specifies.
Short name set inArticle 224, paragraph (2)· applies only in this article and in Article 226
year of the reductionmachine translation
「減額に係る年」
In Article 226, the year containing the day on which foreign income tax that a resident paid, and for which the resident received the foreign tax credit under Article 95, paragraphs (1) to (3) of the Income Tax Act, is reduced, where the reduction comes within seven years after the year of the credit.
Short name set inArticle 226, paragraph (1)· applies only in this article
credit-eligible foreign income tax to be paidmachine translation
「納付控除対象外国所得税額」
The amount of credit-eligible foreign income tax that a resident is to pay in a year in which a foreign income tax credited under Article 95, paragraphs (1) to (3) of the Income Tax Act within the past seven years is reduced, from which the reduced amount is taken off.
Short name set inArticle 226, paragraph (1)· applies only in this provision and in Article 226, paragraph (3)
amount exceeding the credit limitmachine translation
「控除限度超過額」
In Article 226, paragraph (3), the amount, as defined in Article 224, paragraph (6), by which the credit-eligible foreign income tax (控除対象外国所得税の額) a resident had to pay in each of the three years before the year a foreign income tax was reduced exceeded the total of that year's maximum credit for national tax and for local tax, leaving out any part treated as nonexistent under Article 224, paragraph (3) or Article 225, paragraph (3) or (4).
Short name set inArticle 226, paragraph (3)· applies only in this paragraph
reduced amount of credit-eligible foreign income taxmachine translation
「減額控除対象外国所得税額」
In Article 226, paragraph (3), the amount defined in paragraph (2) of that Article: out of a reduction in a resident's foreign income tax, the part of that tax treated as credit-eligible in the year of the credit, less the part that would have been credit-eligible had the reduced tax applied then.
Short name set inArticle 226, paragraph (3)· applies only in this paragraph