Article 3(1)The amount calculated as specified by a Cabinet Order prescribed in Article 5-2(1) and (3) of the Act shall be the amount specified respectively in the following items for the category of cases listed in the relevant items:

(2)Where a nonresident or foreign corporation that is the trustee of a qualified foreign securities investment trust prescribed in Article 5-2(2) of the Act (hereinafter referred to as a "qualified foreign securities investment trust" in this Article) seeks the application of the provisions of Article 5-2(1) of the Act with respect to interest on book-entry transfer national government bonds or book-entry transfer local government bonds to be received thereby for the trust property under the said qualified foreign securities investment trust, the said nonresident or foreign corporation shall submit, for each qualified foreign securities investment trust accepted thereby, a written application for tax exemption of book-entry transfer national government bonds prescribed in Article 5-2(1)(i)(a) of the Act (hereinafter referred to as a "written application for tax exemption of book-entry transfer national government bonds" in this Article) and a statement of the holding period of book-entry transfer national government bonds prescribed in Article 5-2(1)(i)(b) of the Act (referred to as a "statement of the holding period of book-entry transfer national government bonds" in paragraph (7) to paragraph (9)), or a written application for tax exemption of book-entry transfer local government bonds prescribed in Article 5-2(1)(ii)(a) of the Act (hereinafter referred to as a "written application for tax exemption of book-entry transfer local government bonds" in this Article) and a statement of the holding period of book-entry transfer local government bonds prescribed in Article 5-2(1)(ii)(b) of the Act (referred to as a "statement of the holding period of book-entry transfer local government bonds" in paragraph (7), paragraph (8) and paragraph (11)), to the district director prescribed in prescribed in Article 5-2(1)(i)(a) of the Act pursuant to the provisions of Article 5-2(1)(i)(a) and (b) of the Act, or the district director prescribed in Article 5-2(1)(ii)(a) of the Act pursuant to the provisions of Article 5-2(1)(ii)(a) and (b) of the Act.

(3)Where a nonresident or foreign corporation makes, for the first time, entries or records under the book-entry transfer system (meaning entries or records under the book-entry transfer system prescribed in Article 5-2(5)(vi) of the Act; hereinafter the same shall apply in this Article) with regard to book-entry transfer national government bonds (limited to those bearing interest; hereinafter referred to as "interest-bearing book-entry transfer national government bonds" in this paragraph, paragraph (5) and paragraph (22)) in the account listed respectively in the following items, if the person specified in the relevant items for the category of accounts listed in the relevant items has, when the said entries or records under the book-entry transfer system are made, prepared a document containing the name of the said nonresident or foreign corporation and his/her or its address as prescribed in Article 5-2(1)(i)(a) of the Act (hereinafter referred to as "address" in this paragraph, paragraph (5) and paragraph (22)) and any other matters specified by an Ordinance of the Ministry of Finance (hereinafter referred to as a "document on special measures for book-entry transfer national government bonds" in this paragraph and the next paragraph) and submitted the said document on special measures for book-entry transfer national government bonds to the district director prescribed in Article 5-2(1)(i)(a) of the Act (in the case where the specified book-entry transfer institution, etc. (meaning a specified book-entry transfer institution, etc. prescribed in paragraph (1) of the said Article; hereinafter the same shall apply in this Article) pertaining to the person specified in the relevant items is a specified account management institution prescribed in Article 5-2(5)(ii) of the Act (hereinafter referred to as a "specified account management institution" in this Article), submission shall be made to the said district director via a specified book-entry transfer institution prescribed in paragraph (5)(i) of the said Article (hereinafter referred to as a "specified book-entry transfer institution" in this Article); in the case where the specified book-entry transfer institution, etc. pertaining to the person specified in the relevant items is a specified indirect account management institution prescribed in paragraph (5)(iii) of the said Article (hereinafter referred to as a "specified indirect account management institution" in this Article), submission shall be made to the said district director via [1] the specified account management institution pertaining to the entries or records under the book-entry transfer system regarding the said interest-bearing book-entry transfer national government bonds (in the case where the said specified book-entry transfer institution, etc. pertaining to the person specified in the relevant items makes entries or records under the book-entry transfer system regarding the interest-bearing book-entry transfer national government bonds through any other specified indirect account management institution, submission shall be made via the said other specified indirect account management institution and the specified account management institution pertaining to the entries or records under the book-entry transfer system regarding the said interest-bearing book-entry transfer national government bonds) and [2] a specified book-entry transfer institution), the said nonresident or foreign corporation shall be deemed to have submitted a written application for tax exemption of book-entry transfer national government bonds pursuant to the provisions of Article 5-2(1)(i)(a) of the Act with respect to the said interest-bearing book-entry transfer national government bonds; provided, however, that this shall not apply where the name and address to be entered in the said document on special measures for book-entry transfer national government bonds are inconsistent with the name and address of the said nonresident or foreign corporation for which a confirmation has been provided pursuant to the provisions of paragraph (9) of the said Article (including the cases where it is applied mutatis mutandis pursuant to paragraph (12) of the said Article) with respect to book-entry transfer local government bonds (hereinafter referred to as a "confirmation concerning book-entry transfer local government bonds" in this paragraph, the next paragraph and paragraph (22)) or a confirmation has been provided pursuant to the provisions of Article 41-12(12) of the Act with respect to short-term national government bonds, etc. (meaning national government bonds listed in paragraph (9)(i) to (viii) of the said Article that fall under the category of specified short-term government or company bonds prescribed in the said paragraph, and principal-only book-entry transfer national government bonds and coupon-only book-entry transfer national government bonds prescribed in paragraph (12) of the said Article) (including a confirmation provided pursuant to the provisions of Article 26-18(6); hereinafter referred to as a "confirmation concerning short-term national government bonds, etc." in this Article):

(4)In the case referred to in the preceding paragraph, the head of the business office, etc. of the specified book-entry transfer institution, etc. who has submitted a document on special measures for book-entry transfer national government bonds pursuant to the provisions of the said paragraph shall, without delay after the date of the submission, give a notice of the submission of the document on special measures for book-entry transfer national government bonds to the nonresident or foreign corporation that shall be deemed to have submitted a written application for tax exemption of book-entry transfer national government bonds pursuant to the provisions of the said paragraph (in the case where a confirmation concerning book-entry transfer local government bonds or a confirmation concerning short-term national government bonds, etc. with regard to the said nonresident or foreign corporation is provided by the head of a specified overseas business office, etc. of a qualified foreign intermediary, a notice shall be given to the said nonresident or foreign corporation via the head of the said specified overseas business office, etc.).

(5)Where a nonresident or foreign corporation makes, for the first time, entries or records under the book-entry transfer system with regard to book-entry transfer local government bonds in an account listed respectively in the following items, if the person specified in the relevant items for the category of accounts listed in the relevant items has, when the said entries or records under the book-entry transfer system are made, prepared a document containing the name of the said nonresident or foreign corporation and his/her or its address and any other matters specified by an Ordinance of the Ministry of Finance (hereinafter referred to as a "document on special measures for book-entry transfer local government bonds" in this paragraph and the next paragraph) and submitted the said document on special measures for book-entry transfer local government bonds to the district director prescribed in Article 5-2(1)(ii)(a) of the Act via the person who pays interest on the said book-entry transfer local government bonds (in the case where the specified book-entry transfer institution, etc. pertaining to the person specified in the relevant items is a specified account management institution, submission shall be made to the said district director via a specified book-entry transfer institution and the said person who pays the interest; in the case where the specified book-entry transfer institution, etc. pertaining to the person specified in the relevant items is a specified indirect account management institution, submission shall be made to the said district director via [1] the specified account management institution pertaining to the entries or records under the book-entry transfer system regarding the said interest-bearing book-entry transfer local government bonds (in the case where the said specified book-entry transfer institution, etc. pertaining to the person specified in the relevant items makes entries or records under the book-entry transfer system regarding the interest-bearing book-entry transfer local government bonds through any other specified indirect account management institution, submission shall be made via the said other specified indirect account management institution and the specified account management institution pertaining to the entries or records under the book-entry transfer system regarding the said interest-bearing book-entry transfer local government bonds), [2] a specified book-entry transfer institution, and [3] the said person who pays the interest), the said nonresident or foreign corporation shall be deemed to have submitted a written application for tax exemption of book-entry transfer local government bonds pursuant to the provisions of Article 5-2(1)(ii)(a) of the Act with respect to the said interest-bearing book-entry transfer local government bonds; provided, however, that this shall not apply where the name and address to be entered in the said document on special measures for book-entry transfer local government bonds are inconsistent with the name and address of the said nonresident or foreign corporation for which a confirmation has been provided pursuant to the provisions of paragraph (9) of the said Article (including the cases where it is applied mutatis mutandis pursuant to paragraph (12) of the said Article; hereinafter the same shall apply in this paragraph) with respect to other book-entry transfer local government bonds (hereinafter referred to as a "confirmation concerning other book-entry transfer local government bonds" in this paragraph, the next paragraph and paragraph (23)), a confirmation has been provided pursuant to the provisions of paragraph (9) of the said Article with respect to interest-bearing book-entry transfer national government bonds (hereinafter referred to as a "confirmation concerning interest-bearing book-entry transfer national government bonds" in this paragraph, the next paragraph and paragraph (23)) or a confirmation concerning short-term national government bonds, etc. has been provided:

(6)In the case referred to in the preceding paragraph, the head of the business office, etc. of the specified book-entry transfer institution, etc. who has submitted a document on special measures for book-entry transfer local government bonds pursuant to the provisions of the said paragraph shall, without delay after the date of the submission, give a notice of the submission of the document on special measures for book-entry transfer local government bonds, to the nonresident or foreign corporation that shall be deemed to have submitted a written application for tax exemption of book-entry transfer local government bonds pursuant to the provisions of the said paragraph (in the case where a confirmation concerning other book-entry transfer local government bonds, a confirmation concerning interest-bearing book-entry transfer national government bonds or a confirmation concerning short-term national government bonds, etc. with regard to the said nonresident or foreign corporation is provided by the head of a specified overseas business office, etc. of a qualified foreign intermediary, the notice shall be given to the said nonresident or foreign corporation via the head of the said specified overseas business office, etc.).

(7)The head of a business office, etc. of a specified book-entry transfer institution, etc. or head of a specified overseas business office, etc. of a qualified foreign intermediary shall, where a statement of the holding period of book-entry transfer national government bonds or statement of the holding period of book-entry transfer local government bonds has been submitted, confirm whether or not the holding period and other matters specified by an Ordinance of the Ministry of Finance with regard to the book-entry transfer national government bonds or book-entry transfer local government bonds entered in the said statement of the holding period of book-entry transfer national government bonds or statement of the holding period of book-entry transfer local government bonds are consistent with the day on which entries or records under the book-entry transfer system were made with regard to the book-entry transfer national government bonds or book-entry transfer local government bonds and other matters specified by an Ordinance of the Ministry of Finance as entered or recorded in the books prescribed in Article 5-2(13) of the Act (referred to as the "books for book-entry transfer" in paragraph (9), paragraph (11) and paragraph (24)).

(8)Where a nonresident or foreign corporation submits a statement of the holding period of book-entry transfer national government bonds or a statement of the holding period of book-entry transfer local government bonds via a qualified foreign intermediary to the district director set forth in Article 5-2(1)(i)(b) or (ii)(b) of the Act (including the cases where a qualified foreign intermediary submits the document set forth in the next paragraph pursuant to the provisions of the said paragraph as applied mutatis mutandis pursuant to paragraph (10)), the head of the business office, etc. of the specified book-entry transfer institution, etc. that has received a notice set forth in paragraph (14) of the said Article pursuant to the provisions of the said paragraph shall confirm whether or not the holding period and other matters specified by an Ordinance of the Ministry of Finance with regard to the book-entry transfer national government bonds or book-entry transfer local government bonds entered in the said statement of the holding period of book-entry transfer national government bonds or statement of the holding period of book-entry transfer local government bonds or the said document are consistent with the day on which entries or records under the book-entry transfer system were made with regard to the book-entry transfer national government bonds or book-entry transfer local government bonds and other matters specified by an Ordinance of the Ministry of Finance as entered or recorded in the books prescribed in said paragraph.

(9)Where a specified book-entry transfer institution, etc. has, pursuant to the provisions of Article 5-2(9) of the Act (including the cases where it is applied mutatis mutandis pursuant to paragraph (12) of the said Article), prepared and preserved a copy of a document prescribed in paragraph (9) of the said Article that has been presented thereto by a nonresident or foreign corporation, and the said nonresident or foreign corporation receives payment of interest on the book-entry transfer national government bonds for which he/she or it has made entries or records under the book-entry transfer system through the said specified book-entry transfer institution, etc., if the said specified book-entry transfer institution, etc. has, no later than the day preceding the day on which the said nonresident or foreign corporation is to receive payment of such interest, prepared a document containing the holding period and any other matters specified by an Ordinance of the Ministry of Finance with regard to the book-entry transfer national government bonds held by the said nonresident or foreign corporation based on the books for book-entry transfer that the said specified book-entry transfer institution, etc. keeps, and submitted the document to the district director set forth in paragraph (1)(i)(b) of the said Article (in the case where the said specified book-entry transfer institution, etc. is a specified account management institution, submission shall be made to the said district director via a specified book-entry transfer institution; in the case where the said specified book-entry transfer institution, etc. is a specified indirect account management institution, submission shall be made to the said district director via [1] the specified account management institution pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer national government bonds (in the case where the said specified book-entry transfer institution, etc. makes entries or records under the book-entry transfer system regarding the said book-entry transfer national government bonds through any other specified indirect account management institution, submission shall be made via the said other specified indirect account management institution and specified account management institution pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer national government bonds) and [2] a specified book-entry transfer institution), the said nonresident or foreign corporation shall be deemed to have submitted a statement of the holding period of book-entry transfer national government bonds pursuant to the provisions of item (i)(b) of the said paragraph with respect to the interest receivable thereby.

(10)The provisions of the preceding paragraph shall apply mutatis mutandis where a nonresident or foreign corporation receives payment of interest on the book-entry transfer national government bonds for which he/she or it has made entries or records under the book-entry transfer system through a qualified foreign intermediary.In this case, in the said paragraph, the term "to the district director set forth in paragraph (1)(i)(b) of the said Article" shall be deemed to be replaced with "to the district director set forth in paragraph (1)(i)(b) of the said Article via the specified book-entry transfer institution, etc. pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer national government bonds"; the term "(in the case where the said specified book-entry transfer institution, etc. is a specified account management institution, submission shall be made to the said district director via a specified book-entry transfer institution; in the case where the said specified book-entry transfer institution, etc. is a specified indirect account management institution" shall be deemed to be replaced with "(in the case where the said specified book-entry transfer institution, etc. is a foreign further indirect account management institution prescribed in paragraph (5)(vii) of the said Article (hereinafter referred to as a "foreign further indirect account management institution" in this paragraph"; the term "the specified account management institution pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer national government bonds (" shall be deemed to be replaced with "the foreign indirect account management institution prescribed in paragraph (5)(viii) of the said Article (hereinafter referred to as "foreign indirect account management institution" in this paragraph) pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer national government bonds ("; the term "any other specified indirect account management institution" shall be deemed to be replaced with "any other foreign further indirect account management institution"; and the term "the specified account management institution pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer national government bonds) and [2] a specified book-entry transfer institution" shall be deemed to be replaced with "the foreign indirect account management institution pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer national government bonds) and [2] the specified book-entry transfer institution, etc. pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer national government bonds."

(11)Where a specified book-entry transfer institution, etc. has, pursuant to the provisions of Article 5-2(9) of the Act (including the cases where it is applied mutatis mutandis pursuant to paragraph (12) of the said Article), prepared and preserved a copy of a document prescribed in paragraph (9) of the said Article that has been presented thereto by a nonresident or foreign corporation, and the said nonresident or foreign corporation receives payment of interest on the book-entry transfer local government bonds for which he/she or it has made entries or records under the book-entry transfer system through the said specified book-entry transfer institution, etc., if the said specified book-entry transfer institution, etc. has, no later than the day preceding the day on which the said nonresident or foreign corporation is to receive payment of such interest, prepared a document containing the holding period and any other matters specified by an Ordinance of the Ministry of Finance with regard to the book-entry transfer local government bonds held by the said nonresident or foreign corporation based on the books for book-entry transfer that the said specified book-entry transfer institution, etc. keeps, and submitted the document to the district director set forth in paragraph (1)(ii)(b) of the said Article via the person who pays interest on the said book-entry transfer local government bonds (in the case where the said specified book-entry transfer institution, etc. is a specified account management institution, submission shall be made to the said district director via a specified book-entry transfer institution and the said person who pays the interest; in the case where the specified book-entry transfer institution, etc. is a specified indirect account management institution, submission shall be made to the said district director via [1] the specified account management institution pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer local government bonds (in the case where the said specified book-entry transfer institution, etc. makes entries or records under the book-entry transfer system regarding the said book-entry transfer local government bonds through any other specified indirect account management institution, submission shall be made via the said other specified indirect account management institution and the specified account management institution pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer local government bonds), [2] a specified book-entry transfer institution, and [3] the said person who pays the interest), the said nonresident or foreign corporation shall be deemed to have submitted a statement of the holding period of book-entry transfer local government bonds pursuant to the provisions of item (ii)(b) of the said paragraph with respect to the interest receivable thereby.

(12)The provisions of the preceding paragraph shall apply mutatis mutandis where a nonresident or foreign corporation receives payment of interest on the book-entry transfer local government bonds for which he/she or it has made entries or records under the book-entry transfer system through a qualified foreign intermediary.In this case, in the said paragraph, the term "via the person who pays interest on the said book-entry transfer local government bonds" shall be deemed to be replaced with "via the specified book-entry transfer institution, etc. pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer local government bonds and the person who pays interest on the said book-entry transfer local government bonds"; the term "(in the case where the said specified book-entry transfer institution, etc. is a specified account management institution, submission shall be made to the said district director via a specified book-entry transfer institution and the said person who pays the interest; in the case where the specified book-entry transfer institution, etc. is a specified indirect account management institution" shall be deemed to be replaced with "(in the case where the said specified book-entry transfer institution, etc. is a foreign further indirect account management institution prescribed in paragraph (5)(vii) of the said Article (hereinafter referred to as a "foreign further indirect account management institution" in this paragraph"; the term "the specified account management institution pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer national government bonds (" shall be deemed to be replaced with "the foreign indirect account management institution prescribed in paragraph (5)(viii) of the said Article (hereinafter referred to as a "foreign indirect account management institution" in this paragraph) pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer national government bonds ("; the term "any other specified indirect account management institution" shall be deemed to be replaced with "any other foreign further indirect account management institution"; and the term "the specified account management institution pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer local government bonds), [2] a specified book-entry transfer institution" shall be deemed to be replaced with "the foreign indirect account management institution pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer local government bonds), [2] the specified book-entry transfer institution pertaining to the entries or records under the book-entry transfer system regarding the said book-entry transfer local government bonds."

(13)The interest specified by a Cabinet Order prescribed in Article 5-2(3) of the Act shall be the interest listed as follows:

(14)A person who intends to obtain the approval set forth in Article 5-2(5)(iv) of the Act shall attach, to a document containing the person's name and the location of the person's head office or principal office and any other matters specified by an Ordinance of the Ministry of Finance, a document in which a specified book-entry transfer institution certifies that the person is a foreign account management institution prescribed in paragraph (5)(vii) of the said Article and any other document specified by an Ordinance of the Ministry of Finance, and submit such documents, in the case of book-entry transfer national government bonds, to the district director prescribed in paragraph (1)(i)(a) of the said Article via the specified book-entry transfer institution pertaining to the said book-entry transfer national government bonds, or in the case of book-entry transfer local government bonds, to the district director prescribed in item (ii)(a) of the said paragraph via the specified book-entry transfer institution pertaining to the said book-entry transfer local government bonds and the person who pays interest on the said book-entry transfer local government bonds.

(15)Where a written application set forth in the preceding paragraph has been submitted, the district director shall, when he/she makes a disposition to approve or dismiss the application, give a notice in writing to the person who has submitted the application to that effect.

(16)Where a written application set forth in paragraph (14) has been submitted, if a disposition to approve or dismiss the application has not been made by the final day of the month following the month that includes the day on which the written application was submitted, it shall be deemed that approval has been granted as of the said day.

(17)The district director shall, when he/she makes a disposition to rescind approval pursuant to the provisions of Article 5-2(7) of the Act, give a notice in writing to the person who has obtained the approval to that effect.

(18)With respect to the application of the provisions of paragraph (14) in the case where a person who intends to obtain the approval set forth in Article 5-2(5)(iv) of the Act with regard to book-entry transfer national government bonds has already obtained the approval set forth in paragraph (5)(iv) of the said Article with regard to book-entry transfer local government bonds, in paragraph (14), the term "a specified book-entry transfer institution certifies" shall be deemed to be replaced with "the specified book-entry transfer institution pertaining to book-entry transfer national government bonds certifies"; the term "other matters specified by an Ordinance of the Ministry of Finance" shall be deemed to be replaced with "and a document that certifies that the person has obtained the approval set forth in item (iv) of the said paragraph with regard to book-entry transfer local government bonds"; the term "submit such documents, in the case of book-entry transfer national government bonds, to" shall be deemed to be replaced with "submit such documents to"; the term "to the district director prescribed in paragraph (1)(i)(a) of the said Article via the specified book-entry transfer institution pertaining to the said book-entry transfer national government bonds, or in the case of book-entry transfer local government bonds, to the district director prescribed in item (ii)(a) of the said paragraph via the specified book-entry transfer institution pertaining to the said book-entry transfer local government bonds and the person who pays interest on the said book-entry transfer local government bonds" shall be deemed to be replaced with "to the district director prescribed in paragraph (1)(i)(a) of the said Article via the specified book-entry transfer institution pertaining to the said book-entry transfer national government bonds."In this case, where the written application set forth in paragraph (14) has been submitted, it shall be deemed that the approval set forth in Article 5-2(5)(iv) of the Act has been granted at the time of such submission.

(19)With respect to the application of the provisions of paragraph (14) in the case where a person who intends to obtain the approval set forth in Article 5-2(5)(iv) of the Act with regard to book-entry transfer local government bonds has already obtained the approval set forth in paragraph (5)(iv) of the said Article with regard to book-entry transfer national government bonds, in paragraph (14), the term "a specified book-entry transfer institution certifies" shall be deemed to be replaced with "the specified book-entry transfer institution pertaining to book-entry transfer local government bonds certifies"; the term "other matters specified by an Ordinance of the Ministry of Finance" shall be deemed to be replaced with "and a document that certifies that the person has obtained the approval set forth in paragraph (5)(iv) of the said Article with regard to book-entry transfer national government bonds"; the term "submit such documents, in the case of book-entry transfer national government bonds, to the district director prescribed in paragraph (1)(i)(a) of the said Article via the specified book-entry transfer institution pertaining to the said book-entry transfer national government bonds, or in the case of book-entry transfer local government bonds, to" shall be deemed to be replaced with "submit such documents to"; the term "item (ii)(a) of the said paragraph" shall be deemed to be replaced with "paragraph (1)(ii)(a) of the said Article."In this case, where the written application set forth in paragraph (14) has been submitted, it shall be deemed that the approval set forth in Article 5-2(5)(iv) of the Act has been granted at the time of such submission.

(20)With respect to the application of the provisions of paragraph (14) in the case where a person who intends to obtain the approval set forth in Article 5-2(5)(iv) of the Act with regard to book-entry transfer local government bonds has already obtained the approval set forth in paragraph (5)(iv) of the said Article with regard to other book-entry transfer local government bonds, in paragraph (14), the term "a document in which a specified book-entry transfer institution certifies that the person is a foreign account management institution prescribed in paragraph (5)(vii) of the said Article and any other document specified by an Ordinance of the Ministry of Finance" shall be deemed to be replaced with "a document that certifies that the person has obtained the approval set forth in paragraph (5) (iv) of the said Article with regard to other book-entry transfer local government bonds"; the term "submit such documents, in the case of book-entry transfer national government bonds, to the district director prescribed in paragraph (1)(i)(a) of the said Article via the specified book-entry transfer institution pertaining to the said book-entry transfer national government bonds, or in the case of book-entry transfer local government bonds, to" shall be deemed to be replaced with "submit such documents to"; the term "item (ii)(a) of the said paragraph" shall be deemed to be replaced with "paragraph (1)(ii)(a) of the said Article."In this case, where the written application set forth in paragraph (14) has been submitted, it shall be deemed that the approval set forth in Article 5-2(5)(iv) of the Act has been granted at the time of such submission.

(21)The document specified by a Cabinet Order prescribed in Article 5-2(9) of the Act shall be any of the documents specified respectively in the following items for the category of persons listed in the relevant items (in the case where the person listed in the relevant items is the trustee of a qualified foreign securities investment trust, any of the documents specified in the relevant items and the prospectus of the said qualified foreign securities investment trust or any other document similar thereto):

(22)Where a nonresident or foreign corporation makes, for the first time, entries or records under the book-entry transfer system regarding interest-bearing book-entry transfer national government bonds in the account pertaining to the entries or records under the book-entry transfer system covered by a confirmation concerning book-entry transfer local government bonds or the account pertaining to the entries or records under the book-entry transfer system covered by a confirmation concerning short-term national government bonds, etc., or submits a written application prescribed in Article 5-2(10) of the Act pursuant to the provisions of paragraph (10) of the said Article with regard to interest-bearing book-entry transfer national government bonds (hereinafter referred to as a "written application for a change of book-entry transfer national government bonds" in this paragraph, paragraph (24) and paragraph (25)), in terms of the said entries and records under the book-entry transfer system or submission, the fact that the identification documents set forth Article 5-2(9) of the Act (including the cases where it is applied mutatis mutandis pursuant to paragraph (12) of the said Article; hereinafter the same shall apply in this paragraph) have been presented pursuant to the provisions of paragraph (9) of the said Article with regard to a confirmation concerning book-entry local government bonds or that the identification documents set forth in Article 41-12(12) of the Act have been presented pursuant to the provisions of paragraph (12) of the said Article with regard to a confirmation concerning short-term national government bonds, etc. (including the cases where the identification documents set forth in Article 26-18(5) have been presented pursuant to the provisions of paragraph (5) of the said Article) shall be deemed to mean that the document specified by a Cabinet Order set forth in Article 5-2(9) of the Act has been presented pursuant to the provisions of paragraph (9) of the said Article, and the fact that a confirmation concerning the said book-entry transfer local government bonds or a confirmation concerning the said short-term national government bonds, etc. has been provided shall be deemed to mean that a confirmation has been provided pursuant to the provisions of the said paragraph, respectively; provided, however, that this shall not apply where the name and address entered in a written application for tax exemption of book-entry transfer national government bonds or a written application for a change of book-entry transfer national government bonds to be submitted by the said nonresident or foreign corporation are inconsistent with the name and address of the said nonresident or foreign corporation for which a confirmation concerning the said book-entry transfer local government bonds or a confirmation concerning the said short-term national government bonds, etc. has been provided.

(23)The provisions of the preceding paragraph shall apply mutatis mutandis where a nonresident or foreign corporation makes, for the first time, entries or records under the book-entry transfer system regarding book-entry transfer local government bonds in the account pertaining to the entries or records under the book-entry transfer system covered by a confirmation concerning other book-entry transfer local government bonds, the account pertaining to the entries or records under the book-entry transfer system covered by a confirmation concerning interest-bearing book-entry transfer national government bonds or the account pertaining to the entries or records under the book-entry transfer system covered by a confirmation concerning short-term national government bonds, etc., or submits a written application prescribed in Article 5-2(11) of the Act pursuant to the provisions of paragraph (11) of the said Article with regard to book-entry transfer local government bonds (such written application shall be referred to as a "written application for a change of book-entry transfer local government bonds" in paragraph (26)).In this case, in the preceding paragraph, the term "pursuant to the provisions of paragraph (9) of the said Article with regard to a confirmation concerning the said book-entry local government bonds" shall be deemed to be replaced with "pursuant to the provisions of paragraph (9) of the said Article with regard to a confirmation concerning other book-entry local government bonds or a confirmation concerning interest-bearing book-entry transfer national government bonds"; the term "a confirmation concerning the said book-entry transfer local government bonds or" shall be deemed to be replaced with "a confirmation concerning other book-entry transfer local government bonds, a confirmation concerning the said interest-bearing book-entry transfer national government bonds or"; the term "a written application for tax exemption of book-entry transfer national government bonds or written application for a change of book-entry transfer national government bonds" shall be deemed to be replaced with "a written application for tax exemption of book-entry transfer local government bonds or written application for a change of book-entry transfer local government bonds."

(24)When a person who has submitted a written application for tax exemption of book-entry transfer national government bonds (including one who shall be deemed to have submitted a written application for tax exemption of book-entry transfer national government bonds pursuant to the provisions of paragraph (3); hereinafter the same shall apply in this paragraph, the next paragraph and paragraph (28)) has made entries or records under the book-entry transfer system regarding book-entry transfer national government bonds through a specified book-entry transfer institution, etc. or qualified foreign intermediary, or submitted a written application for a change of book-entry transfer national government bonds to a specified book-entry transfer institution, etc. or qualified foreign intermediary, the said specified book-entry transfer institution, etc. or qualified foreign intermediary shall, on each occasion, for each person who has submitted the said written application for tax exemption of book-entry transfer national government bonds (in the case where the person who has submitted the said written application for tax exemption of book-entry transfer national government bonds is the trustee of a qualified foreign securities investment trust, for each person who has submitted the said written application for tax exemption of book-entry transfer national government bonds and for each qualified foreign securities investment trust accepted thereby), enter or record in the books for book-entry transfer the matters prescribed in Article 5-2(13) of the Act, and preserve the said books for book-entry transfer pursuant to the provisions of an Ordinance of the Ministry of Finance.

(25)When a person who has submitted a written application for tax exemption of book-entry transfer national government bonds has made entries or records under the book-entry transfer system regarding book-entry transfer national government bonds through a qualified foreign intermediary, or submitted a written application for a change of book-entry transfer national government bonds to a qualified foreign intermediary, the said qualified foreign intermediary shall, for each person who has submitted the said written application for tax exemption of book-entry transfer national government bonds (in the case where the person who has submitted the said written application for tax exemption of book-entry transfer national government bonds is the trustee of a qualified foreign securities investment trust, for each person who has submitted the said written application for tax exemption of book-entry transfer national government bonds and for each qualified foreign securities investment trust accepted thereby), notify the matters prescribed in Article 5-2(14) of the Act to the specified book-entry transfer institution, etc. prescribed in the said paragraph of the said qualified foreign intermediary pertaining to the said book-entry transfer national government bonds.

(26)The provisions of paragraph (24) shall apply mutatis mutandis where a person who has submitted a written application for tax exemption of book-entry transfer local government bonds (including one who shall be deemed to have submitted a written application for tax exemption of book-entry transfer local government bonds pursuant to the provisions of paragraph (5); hereinafter the same shall apply in this paragraph and paragraph (28)) has made entries or records under the book-entry transfer system regarding book-entry transfer local government bonds through a specified book-entry transfer institution, etc. or qualified foreign intermediary, or submitted a written application for a change of book-entry transfer local government bonds to a specified book-entry transfer institution, etc. or qualified foreign intermediary; and the provisions of the preceding paragraph shall apply mutatis mutandis where a person who has submitted a written application for tax exemption of book-entry transfer local government bonds has made entries or records under the book-entry transfer system regarding book-entry transfer local government bonds through a qualified foreign intermediary, or submitted a written application for a change of book-entry transfer local government bonds to a qualified foreign intermediary.In this case, in paragraph (24), the term "the said written application for tax exemption of book-entry transfer national government bonds" shall be deemed to be replaced with "the said written application for tax exemption of book-entry transfer local government bonds"; in the preceding paragraph, the term "the said written application for tax exemption of book-entry transfer national government bonds" shall be deemed to be replaced with "the said written application for tax exemption of book-entry transfer local government bonds," and the term "pertaining to the said book-entry transfer national government bonds" shall be deemed to be replaced with "pertaining to the said book-entry transfer local government bonds."

(27)The means specified by a Cabinet Order prescribed in Article 5-2(14) of the Act shall be a means of using an electronic data processing system or another means of using information and communications technology that is specified by an Ordinance of the Ministry of Finance.

(28)Where a specified book-entry transfer institution, etc. has received the notice prescribed in paragraph (25) (including the cases where it is applied mutatis mutandis pursuant to paragraph (26)), it shall, on each occasion of receiving the notice, for each person who has submitted a written application for tax exemption of book-entry transfer national government bonds or written application for tax exemption of book-entry transfer local government bonds (in the case where the person who has submitted the said written application for tax exemption of book-entry transfer national government bonds or written application for tax exemption of book-entry transfer local government bonds is the trustee of a qualified foreign securities investment trust, for each person who has submitted the said written application for tax exemption of book-entry transfer national government bonds or written application for tax exemption of book-entry transfer local government bonds and for each qualified foreign securities investment trust accepted thereby), enter or record in the books prescribed in Article 5-2(14) of the Act the matters mentioned in the said notice, and preserve the said books pursuant to the provisions of an Ordinance of the Ministry of Finance.

(29)The national government bonds specified by a Cabinet Order prescribed in Article 5-2(15)(i) of the Act shall be the book-entry transfer national government bonds specified respectively in the following items for the category of persons listed in the relevant items:

(30)The means specified by a Cabinet Order prescribed in Article 5-2(15)(iii) of the Act shall be a means of using an electronic data processing system or another means of using information and communications technology that is specified by an Ordinance of the Ministry of Finance.

(31)A specified book-entry transfer institution, etc. pertaining to the entries or records under the book-entry transfer system regarding the book-entry transfer national government bonds held by a nonresident or foreign corporation shall, where it has received the notice pursuant to the provisions of Article 5-2(15)(iii) of the Act by means of a document, preserve the said document pursuant to the provisions of an Ordinance of the Ministry of Finance.

(32)The specified book-entry transfer institution, etc. set forth in the preceding paragraph shall, where it has received the notice pursuant to the provisions of Article 5-2(15)(iii) of the Act by the means prescribed in paragraph (30), preserve the document or microfilm produced by outputting the matters contained in the said notice using input-output devices of an electronic data processing system prescribed in said paragraph (limited to those specified by an Ordinance of the Ministry of Finance), pursuant to the provisions of an Ordinance of the Ministry of Finance.

(33)The national government bonds specified by a Cabinet Order prescribed in Article 5-2(16)(i) of the Act shall be the book-entry transfer national government bonds specified respectively in the following items for the category of persons listed in the relevant items:

(34)The means specified by a Cabinet Order prescribed in Article 5-2(16)(iii) of the Act shall be a means of using an electronic data processing system or another means of using information and communications technology that is specified by an Ordinance of the Ministry of Finance.

(35)The provisions of paragraph (31) shall apply mutatis mutandis where the said specified book-entry transfer institution, etc. has received the notice pursuant to Article 5-2(16)(iii) of the Act by means of a document.

(36)The specified book-entry transfer institution, etc. set forth in paragraph (31) as applied mutatis mutandis pursuant to the preceding paragraph shall, where it has received the notice pursuant to the provisions of Article 5-2(16)(iii) of the Act by the means prescribed in paragraph (34), preserve the document or microfilm produced by outputting the matters contained in the said notice using input-output devices of an electronic data processing system prescribed in said paragraph (limited to those specified by an Ordinance of the Ministry of Finance), pursuant to the provisions of an Ordinance of the Ministry of Finance.

Article 3-2(1)The person in charge of handling payment as specified by a Cabinet Order prescribed in Article 6(4) of the Act shall be the person prescribed in Article 2-2(2) who is in Japan, and the person who provides, outside Japan, intermediary, brokerage or agent services (referred to as the "intermediary services, etc." in paragraph (10) and paragraph (24)) for the receipt of interest on foreign-issued company bonds prescribed in Article 6(1) of the Act (referred to as "foreign-issued company bonds" in paragraph (22)) as the person's own operations or in relation to such operations.

(2)A written application for tax exemption pursuant to the provisions of Article 6(4) of the Act (referred to as a "written application for tax exemption" in the next paragraph to paragraph (6)) shall be submitted, on each occasion of receiving payment of interest on general foreign-issued company bonds prescribed in paragraph (1) of the said Article (referred to as "general foreign-issued company bonds" in paragraph (4) to paragraph (6), paragraph (23) and paragraph (24)), to the district director prescribed in Article 6(4) of the Act, via the person who pays the interest (in the case where the said interest is paid via a person in charge of handling payment as prescribed in paragraph (4) of the said Article (hereinafter referred to as a "person in charge of handling payment" in this Article), submission shall be made via the said person in charge of handling payment and the person who pays the interest).

(3)A person who submits a written application for tax exemption shall, upon submitting it, present a document that certifies that the person falls under the category of nonresidents or foreign corporations (limited to such document that contains the name and domicile or residence or the location of the person's head office or principal office (hereinafter referred to as "domicile, etc." in this paragraph, the next paragraph and paragraph (8)), each of which is located outside Japan; the same shall apply in paragraph (8)), to a person who pays interest based on the said written application for tax exemption (in the case where the said interest is paid via a person in charge of handling payment, the document shall be presented to the said person in charge of handling payment; hereinafter the same shall apply in this paragraph and the next paragraph), and the said person who pays interest shall confirm, by the document presented thereto, the name and domicile, etc. located outside Japan as entered in the said written application for tax exemption.

(4)A person who pays interest on general foreign-issued company bonds shall, when he/she has confirmed, by the document prescribed in the preceding paragraph, the name or domicile etc. located outside Japan as entered in the written application for tax exemption pertaining to the interest on the said general foreign-issued company bonds which has been submitted thereto, enter in the said written application for tax exemption to that effect that such confirmation has been provided as well as the name and domicile, etc. of the said person who pays interest.

(5)A person who pays interest on general foreign-issued company bonds shall, when he/she has received a written application for tax exemption pertaining to the interest on the said general foreign-issued company bonds, submit the said written application for tax exemption to the district director prescribed in Article 6(4) of the Act no later than the final day of the month that includes the day on which the person has received the written application.

(6)A person who pays interest on general foreign-issued company bonds shall, when he/she has received a written application for tax exemption pertaining to the interest on the said general foreign-issued company bonds, prepare and preserve a copy of the said written application for tax exemption (including its equivalent), pursuant to the provisions of an Ordinance of the Ministry of Finance.

(7)The interest specified by a Cabinet Order prescribed in Article 6(4) and (10) of the Act shall be the interest listed as follows:

(8)A nonresident or foreign corporation who seeks the application of Article 6(7) of the Act with respect to interest on specified foreign-issued company bonds prescribed in paragraph (7) of the said Article (hereinafter referred to as "specified foreign-issued company bonds" through to paragraph (18)) shall, upon entrusting a person in charge of handling payment with custody of the said specified foreign-issued company bonds, pursuant to the provisions of an Ordinance of the Ministry of Finance, notify the said person in charge of handling payment of his/her or its name and domicile, etc. located outside Japan, and obtain a confirmation with regard to the matters contained in the notification, by presenting a document that certifies that he/she or it falls under the category of nonresidents or foreign corporations or by any other method equivalent thereto.

(9)Where a nonresident or foreign corporation who seeks the application of Article 6(7) of the Act with respect to interest on specified foreign-issued company bonds entrusts a person in charge of handling payment with custody of the said specified foreign-issued company bonds, if he/she or it has already obtained a confirmation pursuant to the provisions of the preceding paragraph when entrusting the said person in charge of handling payment with custody of other specified foreign-issued company bonds or the case falls under any of those specified by an Ordinance of the Ministry of Finance as equivalent thereto, notwithstanding the provisions of the said paragraph, the nonresident or foreign corporation shall not be required to give a notification pursuant to the provisions of the said paragraph when entrusting custody of the said specified foreign-issued company bonds.

(10)The person in charge of handling custody and payment prescribed in Article 6(7) of the Act (hereinafter referred to as the "person in charge of handling custody and payment" through to paragraph (15)) shall, on each occasion of receiving the delivery of interest on specified foreign-issued company bonds, of which the person is entrusted with custody, in the course of the intermediary services, etc. for the receipt of such interest, no later than the day preceding the day on which the person is to receive the delivery, give a notice pursuant to the provisions of paragraph (7) of the said Article (hereinafter referred to as a "notice" through to paragraph (12)) to provide interest recipient information prescribed in paragraph (7) of the said Article (hereinafter referred to as "interest recipient information" through to paragraph (16)) which pertains to the interest to be delivered thereto to the person who pays the interest (in the case where the interest is delivered via any other person in charge of handling payment with whom the said person in charge of handling custody and payment has further entrusted custody, a notice shall be given to the person who pays the interest via such other person in charge of handling payment).In this case, if the person in charge of handling custody and payment receives the delivery of interest on the said specified foreign-issued company bonds, for the first time, on or after the day on which 40 days have elapsed since the day on which the said specified foreign-issued company bonds were issued, the notice of interest recipient information pertaining to the interest to be delivered thereto shall be given on or after the said day on which the 40-day period has expired.

(11)Where a person in charge of handling custody and payment receives the delivery of interest on specified foreign-issued company bonds, of which the person is entrusted with custody, on or after the day on which the person has received the delivery of interest pertaining to the interest recipient information of which the said person gave a notice to the person who pays interest on the said specified foreign-issued company bonds (limited to such information provided in the notice stating to the effect that Article 6(7)(i) of the Act shall apply; hereinafter the same shall apply in this paragraph), if the person in charge of handling custody and payment has confirmed that all persons who are to receive payment of the interest (excluding interest subject to the provisions of Article 3-3(3) or (6) of the Act; hereinafter the same shall apply in this paragraph) to be delivered thereto fall under the category of nonresidents or foreign corporations, the said person in charge of handling custody and payment may omit to give a notice of interest recipient information pertaining to the interest to be delivered thereto.

(12)The provisions of the preceding paragraph shall apply only where the person in charge of handling custody and payment set forth in the said paragraph has obtained approval in advance, pursuant to the provisions of an Ordinance of the Ministry of Finance, from the person who pays interest set forth in the said paragraph with regard to the omission of a notice prescribed in the said paragraph.In this case, if the said person in charge of handling custody and payment has not given, by the day preceding the day on which the person is to receive the delivery of interest on the relevant specified foreign-issued company bonds, a notice of interest recipient information pertaining to the interest to be delivered thereto, a notice of interest recipient information shall be deemed to have been given, as of the said day, by the said person in charge of handling custody and payment to the person who pays interest, stating to the effect that Article 6(7)(i) of the Act shall apply.

(13)Where a person in charge of handling custody and payment is entrusted by subcontract with custody of other specified foreign-issued company bonds with the same brand as that of the specified foreign-issued company bonds of which the person is directly entrusted with custody, when the person has received a notice, as the relay point via which the notice shall be given pursuant to the provisions of Article 6(7) of the Act, with regard to the interest recipient information pertaining to the interest on the said other specified foreign-issued company bonds, the person may, pursuant to the provisions of an Ordinance of the Ministry of Finance, give a notice to provide the interest recipient information pertaining to the specified foreign-issued company bonds of which the person is directly entrusted with custody together with the interest recipient information of which the person has received a notice as such relay point, to the person who pays the interest (in the case where the interest is delivered via any other person in charge of handling payment with whom the said person in charge of handling custody and payment has further entrusted custody, a notice shall be given to the person who pays the interest via such other person in charge of handling payment).In this case, the said notice shall be deemed to be a notice of interest recipient information given pursuant to the provisions of paragraph (7) of the said Article.

(14)When a person who is entrusted by subcontract with custody of specified foreign-issued company bonds (excluding such person who is deemed to be a person in charge of handling custody and payment who is entrusted with custody of other specified foreign-issued company bonds with the same brand as that of the said specified foreign-issued company bonds; hereinafter referred to as a "person in charge of handling payment based on entrustment by subcontract" in this paragraph and the next paragraph) has received a notice, as the relay point via which the notice shall be given pursuant to the provisions of Article 6(7) of the Act, with regard to two or more pieces of interest recipient information pertaining to the interest on the said specified foreign-issued company bonds, the person may, pursuant to the provisions of an Ordinance of the Ministry of Finance, give a notice to provide these pieces of interest recipient information of which the person has received a notice as such relay point together, to the person who pays the interest (in the case where the interest is delivered via any other person in charge of handling payment with whom the said person in charge of handling custody and payment has further entrusted custody, a notice shall be given to the person who pays the interest via such other person in charge of handling payment).In this case, the said notice shall be deemed to be a notice of interest recipient information given pursuant to the provisions of paragraph (7) of the said Article.

(15)The provisions of paragraph (11) and paragraph (12) shall apply mutatis mutandis in the following cases:

(16)A person who pays interest on specified foreign-issued company bonds shall, when paying such interest, prepare an interest recipient confirmation document prescribed in Article 6(7) of the Act (hereinafter referred to as an "interest recipient confirmation document" in the next paragraph) based on the interest recipient information provided in the notice given thereto pursuant to the provisions of paragraph (10), paragraph (13) or paragraph (14) (including the interest recipient information of which a notice shall be deemed to have been given pursuant to the provisions of paragraph (12) (including the cases where it is applied mutatis mutandis pursuant to the preceding paragraph)).

(17)A person who pays interest on specified foreign-issued company bonds shall submit an interest recipient confirmation document prepared pursuant to the provisions of the preceding paragraph to the district director prescribed in Article 6(7) of the Act no later than the final day of the month following the month that includes the day on which the interest pertaining to the said interest recipient confirmation document has been paid.

(18)A person who pays interest on specified foreign-issued company bonds shall enter in the books the interest recipient information provided in the notice given thereto pursuant to the provisions of paragraph (16), and preserve the said books pursuant to the provisions of an Ordinance of the Ministry of Finance.

(19)The financial institution or financial instruments business operator specified by a Cabinet Order prescribed in Article 6(8) of the Act shall be any of the following:

(20)The provisions of paragraph (2) to paragraph (6), and paragraph (8) to paragraph (18) shall apply mutatis mutandis where a domestic financial institution, etc. prescribed in Article 6(8) of the Act shall be subject to the provisions of the main clause of paragraph (4) of the said Article as well as paragraph (6) and paragraph (7) of the said Article, all of which shall be applied mutatis mutandis pursuant Article 6(8) of the Act.In this case, in paragraph (3), the term "the name and domicile or residence or the location of the person's head office or principal office (hereinafter referred to as "domicile, etc." in this paragraph, the next paragraph and paragraph (8)), each of which is located outside Japan" and the term "name and domicile, etc. located outside Japan" shall be deemed to be replaced with "name and the location of the person's head office or principal office"; in paragraph (4) and paragraph (8), the term "name and domicile, etc. located outside Japan" shall be deemed to be replaced with "name and the location of the person's head office or principal office"; and in paragraph (11), the term "nonresident or foreign corporation" shall be deemed to be replaced with "nonresident or foreign corporation, or domestic financial institution, etc. prescribed in Article 6(8) of the Act."

(21)The state designated by a Cabinet Order prescribed in Article 6(11) of the Act shall be Switzerland.

(22)The requirements specified by a Cabinet Order prescribed in Article 6(11) of the Act shall be the requirements listed as follows:

(23)With respect to the application of the provisions of Article 267(2) of the Order for Enforcement of the Income Tax Act in the case where a resident who has, in a given year, interest income from interest (excluding interest subject to the provisions of Article 3-3(1) of the Act) on general foreign-issued company bonds, submits a final return form prescribed in Article 267(2) of the said Act, the term "written statement" in paragraph (2) of the said Article shall be deemed to be replaced with "written statement or any other document specified by an Ordinance of the Ministry of Finance."

(24)A person who pays interest on specified foreign-issued company bonds may request a person in charge of handling payment in Japan to give a notice thereto of the part of the amount of interest on the relevant foreign-issued company bonds delivered by the said person in charge of handling payment in the course of intermediary services, etc. for the receipt of such interest, which is subject to the provisions of Article 3-3(3) or (6) of the Act.

(25)The provisions of the preceding paragraphs shall apply mutatis mutandis where the provisions of Article 6(1) to (12) of the Act as applied mutatis mutandis pursuant to paragraph (13) of the said Article shall apply with respect to interest on bonds in foreign currency prescribed in the said paragraph.

Article 25-19(1)The affiliated foreign company specified by a Cabinet Order prescribed in Article 40-4(1) of the Act shall be any of the following:

(2)Whether or not an affiliated foreign company falls under the category of an affiliated foreign company set forth in item (ii) of the preceding paragraph shall be determined as specified as follows:

(3)A nonresident who has a special relationship specified by a Cabinet Order with a resident or domestic corporation prescribed in Article 40-4(2)(i) of the Act shall be a nonresident listed as follows:

Article 25-20(1)The amount of undistributed income calculated in accordance with the standards specified by a Cabinet Order prescribed in Article 40-4(2)(ii) of the Act shall be the remaining amount after deducting the amount listed in Article 39-15(1)(iii) pertaining to the income of a specified foreign subsidiary company, etc. prescribed in Article 40-4(1) of the Act (hereinafter referred to as a "specified foreign subsidiary company, etc." in this Article and paragraph (1) to paragraph (4) of the next Article) in its settlement of accounts for the relevant business year from the sum of the amount listed in Article 39-15(1)(i) and the amount listed in item (ii) of the said paragraph pertaining to the said income (where the amount listed in item (i) of the said paragraph pertaining to the said income is a loss, the said amount of undistributed income shall be the remaining amount after deducting the sum of the said amount of loss and the amount listed in item (iii) of the said paragraph pertaining to the said income from the amount listed in item (ii) of the said paragraph pertaining to the said income).

(2)Notwithstanding the provisions of the preceding paragraph, a resident listed in the items of Article 40-4(1) of the Act may deem that the amount obtained by adding the amount of income calculated pursuant to the provisions of the laws and regulations concerning corporate income taxes in the state of the head office of a specified foreign subsidiary company, etc. (meaning taxes to be imposed based on the amount of the company's income in the state of the head office or in a state or territory other than the state of the head office or by local entities in such state or territory including the state of the head office (including taxes listed in the items of Article 141(2) of the Order for Enforcement of the Corporation Tax Act to be imposed in such state or territory or by local entities of such state or territory) and taxes equivalent to incidental taxes to be imposed incidentally as prescribed in Article 2(xlv) of the Corporation Tax Act (excluding interest tax) and other taxes similar to the tax equivalent to the said incidental taxes; hereinafter the same shall apply in this Section) (where there are two or more laws and regulations concerning the said corporate income taxes, pursuant to the provisions of the principal ones; hereinafter referred to as the "laws and regulations of the state of the head office" in this paragraph), with regard to the income of the said specified foreign subsidiary company, etc. in its settlement of accounts for the relevant business year (where the provisions of Article 66-4(1) or Article 68-88(1) of the Act are applied to a transaction between the said specified foreign subsidiary company, etc. and a domestic corporation listed in the items of Article 66-6(1) of the Act that relates to the said specified foreign subsidiary company, etc., the amount of income calculated pursuant to the provisions of the laws and regulations of the state of the head office by deeming that the transaction was carried out at the arm's length price prescribed in those provisions), and the sum of the amounts listed in Article 39-15(2)(i) to (xiii) pertaining to the said calculated amount of income and then deducting therefrom the sum of the amounts listed in item (xiv) to item (xvi) of the said paragraph pertaining to the said calculated amount of income (where the amount calculated pursuant to the provisions of the laws and regulations of the state of the head office proves to be a loss, the said amount shall be the remaining amount after deducting the sum of the said amount of loss and the amounts listed in item (xiv) to item (xvi) of the said paragraph pertaining to the said calculated amount from the sum of the amounts listed in item (i) to item (xiii) of the said paragraph pertaining to the said calculated amount) shall be the amount calculated in accordance with the standards specified by a Cabinet Order prescribed in Article 40-4(2)(ii) of the Act.

(3)Where there is any amount of a deductible dividend, etc. (meaning the amount equivalent to the amount specified respectively in the following items for the category of cases listed in the relevant items; hereinafter the same shall apply in this paragraph) for the relevant business year of a specified foreign subsidiary company, etc. related to a resident listed in the items of Article 40-4(1) of the Act, the amount calculated in accordance with the standards specified by a Cabinet Order prescribed in Article 40-4(2)(ii) of the Act shall be the remaining amount after deducting the said amount of a deductible dividend, etc. from the amount calculated pursuant to these provisions, notwithstanding the provisions of paragraph (1) or the preceding paragraph:

(4)In the preceding paragraph and this paragraph, the meanings of the terms listed respectively in the following items shall be as specified respectively in the relevant items:

(5)The amount obtained as a result of an adjustment for the amount of loss prescribed in Article 40-4(2)(ii) of the Act shall be the amount obtained by calculating the amount of income pursuant to the provisions of paragraph (1), (2) or (3) with regard to the income of a specified foreign subsidiary company, etc. in its settlement of accounts for the relevant business year (hereinafter referred to as the "amount of adjusted income" in this paragraph and paragraph (7)) and then deducting therefrom the amount equivalent to the sum of the loss incurred in business years that commenced within seven years preceding the first day of the relevant business year (excluding a business year that commenced before April 1, 1978 and a business year during which the company did not fall under the category of a specified foreign subsidiary company, etc. (including a specified foreign subsidiary company, etc. prescribed in Article 66-6(1) or Article 68-90(1) of the Act)) (such loss shall exclude the amount deducted in the business years preceding the said relevant business year pursuant to the provisions of this paragraph) (where the said sum of the loss exceeds the amount of adjusted income for the relevant business year, the said amount of adjusted income).

(6)The loss prescribed in the preceding paragraph shall be the loss calculated where the provisions of paragraph (1), paragraph (2) or paragraph (3) are applied to the amount of income of a specified foreign subsidiary company, etc. in its settlement of accounts for the relevant business year.

(7)When calculating the amount listed in Article 39-15(1)(i) with regard to the income of a specified foreign subsidiary company, etc. in its settlement of accounts for the relevant business year pursuant to the provisions of paragraph (1), if there is any amount to be included in deductible expenses in the relevant business year, pursuant to the provisions of Article 33 and Article 42 to Article 53 of the Corporation Tax Act and the provisions of Article 43, Article 45-2, Article 52-2, Article 57-5, Article 57-6, Article 57-8, Article 65-7 to Article 65-9 (limited to the part pertaining to item (xix) of the table in Article 65-7(1) of the Act), Article 67-12(2) and Article 67-13(2) of the Act, whose provisions shall be applicable under the provisions of the said item, the said amount shall be included in deductible expenses for calculating the amount of adjusted income for the relevant business year, only when detailed statements concerning the inclusion of the said amount in deductible expenses are attached to a final return form; provided, however, that when a final return form has not been submitted or a final return form has been submitted without detailed statements concerning the inclusion of the said amount in deductible expenses, the district director shall, when he/she finds that there was any compelling reason therefor, apply the provisions of the main clause of this paragraph, only when the said detailed statements have been submitted.

(8)Where a resident, who was subject to the provisions of paragraph (1) for calculating the amount of income of the specified foreign subsidiary company, etc. in its settlement of accounts for the relevant business year, seeks the application of paragraph (2) for calculating the amount of income of the said specified foreign subsidiary company, etc. in its settlement of accounts for the relevant business year in years following the one to which the provisions of paragraph (1) have been applied, or where a resident, who was subject to the provisions of paragraph (2) for calculating the amount of income of the specified foreign subsidiary company, etc. in its settlement of accounts for the relevant business year, seeks the application of paragraph (1) for calculating the amount of income of the said specified foreign subsidiary company, etc. in its settlement of accounts for the relevant business year in years following the one to which the provisions of paragraph (2) have been applied, he/she shall receive approval from the competent district director having jurisdiction over his/her place for tax payment, in advance.

Article 25-21(1)The amount obtained as a result of an adjustment to the amount of undistributed income set forth in Article 40-4(1) of the Act for the amount of taxes and a dividend of surplus, etc. on the said undistributed income shall be the remaining amount after deducting the sum of the amounts listed as follows from the amount of undistributed income prescribed in Article 40-4(2)(ii) for the relevant business year of a specified foreign subsidiary company, etc. (hereinafter referred to as the "amount of undistributed income" in this paragraph) (where the amount of corporate income tax to be refunded as prescribed in item (i) exceeds the amount of corporate income tax payable as prescribed in the said item, the amount obtained by adding the amount of undistributed income and the said excess amount and then deducting therefrom the amount listed in item (ii)).In this case, when the sum of the amounts listed in item (i) and item (ii) exceeds the said amount of undistributed income, the amount listed in item (i) shall be deducted first and then the amount listed in item (ii) shall be deducted:

(2)The amount calculated as specified by a Cabinet Order prescribed in Article 40-4(1) of the Act shall be the amount obtained by deducting the sum of the amounts listed in paragraph (4)(i)(b) and (c) of the preceding Article for the relevant business year from the amount of eligible retained income prescribed in Article 40-4(1) of the Act for the relevant business year of a specified foreign subsidiary company, etc. related to a resident listed in the items of the said paragraph (hereinafter such remaining amount after deduction shall be referred to as the "eligible retained income for adjustment" in this paragraph) and then multiplying the said remaining amount by the ratio of the shares, etc. for considering the claims held by the said person out of the total issued shares, etc. of the specified foreign subsidiary company, etc. at the end of the relevant business year of the specified foreign subsidiary company, etc. (where the amount of a dividend of surplus, etc. by deeming the relevant business year to be the base business year has not been deducted for calculating the amount of the said eligible retained income, the amount shall be that obtained by deducting either of the smaller amounts out of those listed in the next items from the said calculated amount):

(3)In the preceding paragraph and this paragraph, the meanings of the terms listed respectively in the following items shall be as specified respectively in the relevant items:

(4)The amount that shall be included in the necessary expenses for calculating the amount of miscellaneous income pertaining to the taxable retained income to be included in the gross revenue pursuant to the provisions of Article 40-4(1) of the Act shall be the sum of the interest on liabilities incurred by a resident in acquiring the shares, etc. of a specified foreign subsidiary company, etc. (including the shares, etc. of a foreign corporation pertaining to the shares, etc. indirectly held by the said resident in the case where he/she indirectly holds the shares, etc. pertaining to the said specified foreign subsidiary company, etc. (such shares, etc. indirectly held shall mean the number of shares or the amount of capital contributions of a foreign corporation specified by a Cabinet Order as those held indirectly as prescribed in Article 40-4(2)(iii) of the Act) (such shares, etc. of a specified foreign subsidiary company, etc. shall be limited to those held by the said resident and exclude those falling under the category of the shares, etc. of a specified foreign subsidiary company, etc. related to the said resident); hereinafter the same shall apply in this paragraph) which shall be paid for a period of the year during which the said resident held the said shares, etc. of the specified foreign subsidiary company, etc. (where the said sum exceeds the amount deemed to be revenue pertaining to the said miscellaneous income under the provisions of paragraph (1) of the said Article, such amount shall be that equivalent to the sum of the amounts deemed to be the said revenue).

(5)The amount of interest on liabilities prescribed in the preceding paragraph which shall be included in the necessary expenses for calculating the amount of miscellaneous income pertaining to the taxable retained income pursuant to the provisions of the said paragraph shall not be included in the amount to be included in the necessary expenses for calculating the amount of business income or miscellaneous income and the amount of interest on liabilities prescribed in Article 24(2) of the Income Tax Act which shall be deducted for calculating the amount of dividend income pursuant to the provisions of the said paragraph.

(6)The number of shares or the amount of capital contributions of a foreign corporation specified by a Cabinet Order as those held indirectly as prescribed in Article 40-4(2)(iii) of the Act shall be the number or the amount of the shares, etc. obtained by multiplying the issued shares, etc. of a foreign corporation by the ratio specified respectively in the following items for the category of cases listed in the relevant items (where falling under both of the following cases, the sum of the ratios specified respectively as follows):

(7)The number of voting rights of a foreign corporation specified by a Cabinet Order as being held indirectly as prescribed in Article 40-4(2)(iv) of the Act shall be the number of voting rights obtained by multiplying the total number of voting rights (meaning the voting rights prescribed in Article 40-4(1)(i)(a) of the Act; hereinafter the same shall apply in this paragraph) by the ratio specified respectively in the following items for the category of cases listed in the relevant items (where falling under both of the following cases, the sum of the ratios specified respectively as follows):

(8)The amount of a dividend of surplus, etc. specified by a Cabinet Order as being receivable based on the claims vested in the shares, etc. of a foreign corporation held indirectly as prescribed in Article 40-4(2)(v) of the Act shall be the amount of a dividend of surplus, etc. obtained by multiplying the total amount of a dividend of surplus, etc. receivable based on the claims vested in the shares, etc. of a foreign corporation by the ratio specified respectively in the following items for the category of cases listed in the relevant items (where falling under both of the following cases, the sum of the ratios specified respectively as follows):

(9)A person who has a special relationship specified by a Cabinet Order with a resident or domestic corporation prescribed in Article 40-4(2)(vi) of the Act shall be an individual or corporation listed as follows:

(10)The provisions of Article 4(3) of the Order for Enforcement of the Corporation Tax Act shall apply mutatis mutandis where governing any other corporation listed in (a) to (c) of item (ii) of the preceding paragraph.

(11)The amount of expenses specified by a Cabinet Order set forth in Article 40-4(1) of the Act which is applied by replacing the terms pursuant to the provisions of paragraph (3) of the said Article shall be the sum of personnel expenses for officers and employees of a specified foreign subsidiary company, etc. engaged in the business of the said specified foreign subsidiary company, etc. prescribed in paragraph (3) of the said Article (limited to the amount to be included in deductible expenses for calculating the amount of income or loss pursuant to the provisions of paragraph (1) or (2) of the preceding Article for the relevant business year of the said specified foreign subsidiary company, etc.).

Article 25-22(1)The person specified by a Cabinet Order prescribed in Article 40-4(4)(i) of the Act shall be any of the following:

(2)The case specified by a Cabinet Order prescribed in Article 40-4(4)(i) of the Act shall be any of the cases specified respectively in the following items, in accordance with the category of the principal business to be conducted for the relevant business year of a specified foreign subsidiary company, etc. prescribed in the said paragraph:

(3)Where transactions prescribed in the preceding paragraph between a specified foreign subsidiary company, etc. and an affiliated person related to the said specified foreign subsidiary company, etc. are conducted indirectly via a person other than an affiliated person related to the said specified foreign subsidiary company, etc. (hereinafter referred to as a "non-affiliated person" in this paragraph), transactions between the said specified foreign subsidiary company, etc. and the said non-affiliated person shall be deemed to have been conducted directly between the said specified foreign subsidiary company, etc. and the said affiliated person and the provisions of the items of the preceding paragraph shall be applied, except in the case where there are justifiable grounds for having the said non-affiliated person intervene in such transactions.

(4)The water areas specified by a Cabinet Order prescribed in Article 40-4(4)(ii) of the Act shall be inland water and territorial sea and exclusive economic zones or water areas equivalent to continental shelves related to a state or territory prescribed in the said item.

(5)The case specified by a Cabinet Order prescribed in Article 40-4(4)(ii) of the Act shall be any of the cases specified respectively in the following items, in accordance with the category of the principal business to be conducted for the relevant business year of a specified foreign subsidiary company, etc. prescribed in the said paragraph:

Article 25-23(1)The affiliated foreign company prescribed in Article 40-5(1) of the Act which is specified by a Cabinet Order shall be one of the affiliated foreign companies which hold the taxed amount of a dividend, etc. before deduction for a specified foreign subsidiary company, etc. prescribed in the said paragraph (hereinafter referred to as a "specified foreign subsidiary company, etc." in this Article and paragraph (2) of the next Article) (such affiliated foreign company shall exclude those falling under the category of a specified foreign subsidiary company, etc. related to a resident set forth in the said paragraph).

(2)The amount calculated as specified by a Cabinet Order prescribed in Article 40-5(1) of the Act shall be the amount specified respectively in the following items for the category of cases listed in the relevant items:

(3)With respect to the application of the provisions of item (i) of the preceding paragraph in the case where payment has been made for s of surplus, etc. whose base dates for payment are included in the base business year, with regard to a specified foreign subsidiary company, etc. related to a resident prescribed in Article 40-5(1) of the Act (where payment was made for the said two or more dividends of surplus, etc. in a year preceding the applicable business year pertaining to the base business year for the said dividends of surplus, etc. (hereinafter such paid dividend of surplus, etc. shall be referred to as a "specified dividend of surplus, etc." in this paragraph), excluding the said two or more dividends of surplus) (including the cases where payment has been made for a specified dividend of surplus, etc. and payment has not been made for a dividend of surplus, etc. whose base date for payment is included in the said base business year up to the day on which six months have elapsed after the final day of the base business year for the said specified dividend of surplus, etc.), the amount specified in item (i) of the preceding paragraph shall be the amount obtained by multiplying the excess amount when the amount listed in item (i) exceeds the amount listed in item (ii) by the ratio prescribed in item (i) of the said paragraph and then deducting therefrom the amounts listed in item (iii) and item (iv):

(4)The taxed amount of a dividend, etc. before deduction prescribed in paragraph (1) and paragraph (2) shall be, out of the amount of a dividend of surplus, etc. which an affiliated foreign company related to a resident prescribed in Article 40-5(1) of the Act received from a specified foreign subsidiary company, etc. related to the said resident during the period of two years or less preceding the day on which an event listed in item (iii) of the said paragraph occurred (such amount of a dividend of surplus, etc. shall include the amount specified in item (ii) of the said paragraph) and which shall not be deducted for calculating the amount of taxable retained income under the provisions of Article 25-21(2) pertaining to the said specified foreign subsidiary company, etc. (including the amount which shall not be included in the taxed amount of a dividend, etc. prescribed in Article 40-5(1) of the Act that was calculated for the said specified foreign subsidiary company, etc. pursuant to the provisions of paragraph (2) or the preceding paragraph), the part which corresponds to the shares, etc. for considering the claims of the said specified foreign subsidiary company, etc. indirectly held by the said resident via the said affiliated foreign company (such part shall exclude the amount already appropriated for the application of the provisions of Article 40-5(1) of the Act).

(5)Deduction of the amount equivalent to the taxed amount of a dividend, etc. under the provisions of Article 40-5(1) of the Act (meaning the taxed amount of a dividend, etc. prescribed in the said paragraph; hereinafter the same shall apply in this Article) shall be made as specified as follows:

(6)The deduction of the amount equivalent to the remaining amount of a dividend, etc. after deduction under the provisions of Article 40-5(2) of the Act (meaning the remaining amount of a dividend, etc. after deduction prescribed in the said paragraph; hereinafter the same shall apply in this paragraph) shall be made as specified as follows:

Article 25-24(1)In the case referred to in Article 40-4(1) of the Act, whether or not a foreign company falls under the category of an affiliated foreign company shall be determined according to its status at the end of the relevant business year of the said foreign corporation and whether or not the person falls under the category of a resident listed in the items of the said paragraph shall be determined according to its status at the end of the relevant business year of an affiliated foreign company related to such resident.

(2)With respect to the application of the provisions of Article 222 of the Order for Enforcement of the Income Tax Act when calculating the maximum amount of deduction prescribed in Article 95(1) of the Income Tax Act for a resident subject to the provisions of Article 40-4(1) of the Act or Article 40-5(1) or (2) of the Act, the amount of miscellaneous income pertaining to the taxable retained income to be included in the gross revenue pursuant to the provisions of Article 40-4(1) of the Act shall be included in the domestic source income prescribed in Article 222(3) of the said Order, and the amount of dividend income from a dividend, etc. prescribed in Article 40-5(1) to be received from a specified foreign subsidiary company, etc. or an affiliated foreign company subject to the provisions of Article 40-5(1) or (2) of the Act shall be the amount of the said dividend income calculated without applying these provisions.

(3)The provisions of Article 14-10(1) to (5) and (7) to (11) of the Order for Enforcement of the Corporation Tax Act shall apply mutatis mutandis where the provisions of Article 40-4(7) of the Act shall apply under the provisions of Article 40-4 (excluding paragraph (3), paragraph (4) and paragraph (6)) to Article 40-6 of the Act and Article 25-19 to Article 25-21 (excluding paragraph (11)), Article 25-23 and this Article.

(4)With regard to a trust corporation or a beneficiary of a trust subject to corporation taxation prescribed in Article 4-7 of the Corporation Tax Act, in addition to what is specified in the preceding paragraph, other necessary matters concerning the application of the provisions of Article 40-4 (excluding paragraph (3), paragraph (4) and paragraph (6)) to Article 40-6 of the Act, or Article 25-19 to Article 25-21 (excluding paragraph (11)), Article 25-23 or this Article shall be specified by an Ordinance of the Ministry of Finance.

Article 25-30(1)An individual who has a special relationship specified by a Cabinet Order prescribed in Article 40-10(1) of the Act shall be any of the following:

(2)A corporation which has a special relationship specified by a Cabinet Order prescribed in Article 40-10(1) of the Act shall be any of the following:

(3)The provisions of Article 4(3) and (4) of the Order for Enforcement of the Corporation Tax Act shall apply mutatis mutandis where the provisions of the preceding paragraph shall apply.

(4)A relationship specified by a Cabinet Order prescribed in Article 40-10(1) of the Act shall be the relevant relationship in the case where a specially-related shareholder, etc. prescribed in the said paragraph (hereinafter referred to as a "specially-related shareholder, etc." in this Section) and a specially-related domestic corporation have a relationship where the ratio of the shares, etc. indirectly held by the specially-related shareholder, etc. pertaining to the specially-related domestic corporation (meaning the ratio specified respectively in the following items for the category of cases listed in the relevant items (where falling under both of the following cases, the sum of the ratios specified respectively as follows)) is 80 percent or more:

(5)A foreign corporation specified by a Cabinet Order prescribed in Article 40-10(1) of the Act shall be any of the following:

(6)In item (iii) of the preceding paragraph, whether or not a foreign corporation directly or indirectly holds over 50 percent of the issued shares, etc. shall be determined based on the sum of the ratio of the shares, etc. held directly by a foreign corporation listed in item (i) and item (ii) of the said paragraph pertaining to any other foreign corporation (excluding a foreign corporation falling under the category of a foreign corporation listed in item (i) or item (ii) of the said paragraph and a foreign corporation falling under the category of a specially-related shareholder, etc.; hereinafter the same shall apply in this paragraph) (such ratio of the shares, etc. held directly shall mean the ratio of the number or the amount of the shares, etc. of any other foreign corporation held by a foreign corporation listed in item (i) and item (ii) of the preceding paragraph out of the total issued shares, etc. of the said other foreign corporation) and the ratio of the shares, etc. held indirectly by a foreign corporation listed in item (i) and item (ii) of the said paragraph pertaining to the said other foreign corporation (such ratio of the shares, etc. held indirectly shall mean the ratio specified respectively in the following items for the category of cases listed in the relevant items (where falling under both of the following cases, the sum of the ratios specified respectively as follows):

(7)An affiliated foreign corporation specified by a Cabinet Order prescribed in Article 40-10(1) of the Act shall be any of the following:

(8)The provisions of Article 25-19(2) shall apply mutatis mutandis to the determination as to whether or not an affiliated foreign corporation falls under the category of an affiliated foreign corporation set forth in item (ii) of the preceding paragraph.

(9)An individual who has the special relationship specified by a Cabinet Order prescribed in Article 40-10(2)(i) of the Act shall be an individual who has a special relationship prescribed in Article 4(1) of the Order for Enforcement of the Corporation Tax Act with a shareholder, etc. of a domestic corporation.

(10)A corporation which has a special relationship specified by a Cabinet Order prescribed in Article 40-10(2)(i) of the Act shall be any of the following:

(11)The provisions of Article 4(3) and (4) of the Order for Enforcement of the Corporation Tax Act shall apply mutatis mutandis where the provisions of the preceding paragraph shall apply.

(12)A domestic corporation specified by a Cabinet Order prescribed in Article 40-10(2)(ii) of the Act shall be a domestic corporation which has received the transfer of almost all the assets and liabilities of a specified domestic corporation prescribed in the said item immediately prior to a merger, split, transfer of business or for other reasons (hereinafter referred to as "specified reasons" in this paragraph) due to the said specified reasons.

Article 25-31(1)The amount of undistributed income calculated in accordance with the standards specified by a Cabinet Order prescribed in Article 40-10(2)(iii) of the Act shall be the amount calculated, pursuant to the provisions of Article 25-20(1) or (2) or paragraph (3) of the said Article, with regard to the income of a specified foreign corporation prescribed in Article 40-10(1) of the Act (hereinafter referred to as a "specified foreign corporation" in this Article and paragraph (1) and paragraph (2) of the next Article) in its settlement of accounts for the relevant business year.

(2)The amount obtained as a result of an adjustment for the amount of a loss prescribed in Article 40-10(2)(iii) of the Act shall be the amount obtained by calculating the amount of income pursuant to the provisions of the preceding paragraph with regard to the income of a specified foreign corporation in its settlement of accounts for the relevant business year (hereinafter referred to as the "amount of adjusted income" in this paragraph) and then deducting therefrom the amount equivalent to the sum of the loss incurred in business years that commenced within seven years preceding the first day of the relevant business year (excluding a business year that commenced before October 1, 2007 and a business year during which the corporation did not fall under the category of a specified foreign corporation (including a specified foreign corporation prescribed in Article 66-9-6(1) or Article 68-93-6(1) of the Act)) (such loss shall exclude the amount deducted in business years preceding the said relevant business year pursuant to the provisions of this paragraph) (where the said sum of the loss exceeds the amount of adjusted income for the relevant business year, the said amount of adjusted income).

(3)A loss prescribed in the preceding paragraph shall be a loss calculated with regard to the amount of income of a specified foreign corporation in its settlement of accounts for the relevant business year, where the calculation has been made pursuant to the provisions of paragraph (1).

(4)The provisions of Article 25-20(7) and (8) shall apply mutatis mutandis where the amount of income of a specified foreign corporation in its settlement of accounts for the relevant business year is calculated pursuant to the provisions of paragraph (1) or (2) of the said Article.

Article 25-32(1)The amount obtained as a result of an adjustment to the amount of undistributed income set forth in Article 40-10(1) of the Act for the amount of taxes and a dividend of surplus, etc. on the said undistributed income shall be the amount calculated with regard to the amount of undistributed income prescribed in Article 40-10(2)(iii) of the Act for the relevant business year of a specified foreign corporation, pursuant to the provisions of Article 25-21(1).

(2)The amount calculated as specified by a Cabinet Order prescribed in Article 40-10(1) of the Act shall be the amount calculated with regard to the eligible retained income (meaning the eligible retained income prescribed in the said paragraph; hereinafter the same shall apply in this Section) for the relevant business year of a specified foreign corporation related to a resident who is a specially-related shareholder, etc., pursuant to the provisions of Article 25-21(2) and (3).

(3)The provisions of Article 25-21(4) and (5) shall apply mutatis mutandis to the case of calculating the amount to be included in the necessary expenses for calculating the amount of miscellaneous income pertaining to taxable retained income prescribed in Article 40-10(1) of the Act which shall be included in the gross revenue pursuant to the provisions of the said paragraph.

(4)The provisions of Article 25-21(6) shall apply mutatis mutandis to the number of shares or the amount of capital contributions of a foreign corporation specified by a Cabinet Order as being held indirectly as prescribed in Article 40-10(2)(iv) of the Act.In this case, the term "an individual" in Article 25-21(6) shall be deemed to be replaced with "a resident."

(5)The amount of expenses specified by a Cabinet Order set forth in Article 40-10(1) of the Act which is applied by replacing the terms pursuant to the provisions of paragraph (3) of the said Article shall be the amount calculated with regard to the sum of personnel expenses for officers and employees of a specified foreign corporation engaged in the business of the said specified foreign corporation prescribed in paragraph (3) of the said Article, pursuant to the provisions of Article 25-21(11).

Article 25-33(1)The person specified by a Cabinet Order prescribed in Article 40-10(4)(i) of the Act shall be any of the following:

(2)The provisions of Article 25-22(2) and (3) shall apply mutatis mutandis to the case specified by a Cabinet Order prescribed in Article 40-10(4)(i) of the Act.In this case, the term "those listed in the items of Article 40-4(1), items of Article 66-6(1), items of Article 68-90(1) of the Act and the preceding items" in Article 25-22(2)(i) shall be deemed to be replaced with "a specially-related domestic corporation prescribed in Article 40-10(2)(ii) of the Act, specially-related shareholder, etc. prescribed in paragraph (1) of the said Article and those listed in the items of Article 25-33(1)."

(3)The provisions of Article 25-22(5) shall apply mutatis mutandis to the case specified by a Cabinet Order prescribed in Article 40-10(4)(ii) of the Act.

Article 25-34(1)The affiliated foreign corporation prescribed in Article 40-11(1) of the Act which is specified by a Cabinet Order shall be one of the affiliated foreign corporations which hold the taxed amount of a dividend, etc. before deduction pertaining to a specified foreign corporation prescribed in Article 40-11(1) of the Act (hereinafter referred to as a "specified foreign corporation" in this paragraph and the next paragraph) (such taxed amount of a dividend, etc. before deduction shall mean the taxed amount of a dividend, etc. before deduction prescribed in Article 25-23(2) to (4) obtained by calculating the amount prescribed in items of Article 40-11(1) of the Act, pursuant to the provisions of Article 25-23(2) to (4), where an event listed in the items of Article 40-11(1) of the Act has occurred with regard to a specified foreign corporation related to a resident who is a specially-related shareholder, etc. or an affiliated foreign corporation related to the said resident, pursuant to the provisions of the next paragraph) (such affiliated foreign corporation shall exclude those falling under the category of a specified foreign corporation related to a resident set forth in Article 40-11(1) of the Act).

(2)The amount calculated as specified by a Cabinet Order prescribed in Article 40-11(1) of the Act shall be the amount obtained by calculating the amount specified in the items of the said paragraph, where an event listed in the items of the said paragraph has occurred with regard to a specified foreign corporation related to a resident who is a specially-related shareholder, etc. or an affiliated foreign corporation related to the said resident as prescribed in the said paragraph, pursuant to the provisions of Article 25-23(2) to (4).

(3)The provisions of Article 25-23(5) and (6) shall apply mutatis mutandis to a deduction under the provisions of Article 40-11(1) of the Act of the amount equivalent to the taxed amount of a dividend, etc. prescribed in the said paragraph and a deduction under paragraph (2) of the said Article of the remaining amount of dividend, etc. after deduction prescribed in the said paragraph.

Article 25-35(1)Where the provisions of Article 40-10(1) of the Act shall apply, whether or not a domestic corporation falls under the category of a specified domestic corporation prescribed in Article 40-10(2)(i) of the Act shall be determined according to its status immediately before an event causing a specified relationship prescribed in paragraph (1) of the said Article occurred, and whether or not the said specified relationship actually exists afterwards between a specially-related shareholder, etc. and a specially-related domestic corporation and whether or not a foreign corporation falls under the category of an affiliated foreign corporation shall be determined according to its status at the end of the relevant business year of the said specially-related domestic corporation.

(2)Where a foreign corporation has been determined as falling under the category of an affiliated foreign corporation at the end of the relevant business year of a specially-related domestic corporation, pursuant to the provision of preceding paragraph, the provisions of Article 40-10 of the Act shall apply to the eligible retained income for the relevant business year including the day on which the said affiliated foreign corporation (limited to that falling under the category of a specified foreign corporation prescribed in Article 40-10(1) of the Act) was determined as falling under such category.

(3)The provisions of Article 25-24(2) shall apply mutatis mutandis to the application of the provisions of Article 222 of the Order for Enforcement of the Income Tax Act in the case of calculating the maximum amount of deduction prescribed in Article 95(1) of the Income Tax Act for a resident subject to the provisions of Article 40-10(1) of the Act or Article 40-11(1) or (2) of the Act.

(4)The provisions of Article 14-10(1) to (5) and (7) to (11) of the Order for Enforcement of the Corporation Tax Act shall apply mutatis mutandis where the provisions of Article 40-10(8) of the Act shall apply under the provisions of Article 40-10 (excluding paragraph (3), paragraph (4) and paragraph (6)) to Article 40-12 of the Act, Article 25-30 to Article 25-32 (excluding paragraph (5)), Article 25-34 and this Article.

(5)With regard to a trust corporation or the beneficiary of a trust subject to corporation taxation prescribed in Article 4-7 of the Corporation Tax Act, in addition to what is specified in the preceding paragraph, other necessary matters concerning the application of the provisions of Article 40-10 (excluding paragraph (3), paragraph (4) and paragraph (6)) to Article 40-12 of the Act, Article 25-30 to Article 25-32 (excluding paragraph (5)), Article 25-34 or this Article shall be specified by an Ordinance of the Ministry of Finance.

Article 26-10(1)The issuer of discount bonds prescribed in Article 41-12(7) of the Act (hereinafter referred to as "discount bonds" through to Article 26-13) shall, when he/she pays income tax collected pursuant to the provisions of Article 41-12(3) of the Act, attach a financial statement specified by an Ordinance of the Ministry of Finance to a payment statement prescribed in Article 34(1) of the Act on General Rules for National Taxes at the time of the payment.

(2)The place for paying income tax to be collected and paid pursuant to the provisions of Article 41-12(3) of the Act shall be at the location of the head office or principal office of an issuer of discount bonds set forth in the said paragraph (where the said discount bonds are national government bonds (excluding those listed in Article 41-12(7)(i) of the Act), at the location of the head office of the Bank of Japan).

(3)The amount deemed to be income tax to be collected when receiving the redemption prescribed in Article 41-12(4) of the Act pursuant to the provisions of the said paragraph shall be the amount of income tax that shall be collected from a person who receives the said redemption, with regard to discount bonds that he/she holds at the time of the said redemption, at the time of issue of the discount bonds pursuant to the provisions of paragraph (3) of the said Article.

Article 26-11(1)The amount of income tax to be deducted from corporation tax out of the amount deemed to be income tax to be collected when receiving the redemption prescribed in Article 41-12(4) of the Act pursuant to the provisions of the said paragraph shall be the amount calculated, pursuant to the provisions of Article 140-2 of the Order for Enforcement of the Corporation Tax Act, with regard to the amount of the said income tax (where the amount of the said income tax is not clear, with regard to the amount obtained by deducting the issue price for the discount bonds (where the said discount bonds are national government bonds listed in Article 41-12(9)(i) to (viii) of the Act which are those falling under the category of short-term government or company bonds prescribed in the said paragraph or other national government bonds specified by an Ordinance of the Ministry of Finance (hereinafter referred to as "short-term national government bonds, etc." in this paragraph) and are discount bonds other than those whose issue price is not clear, such issue price shall be the issue price on the final issue date for the said discount bonds, and where the said discount bonds are the said short-term national government bonds, etc., such issue price shall be the price specified by an Ordinance of the Ministry of Finance as equivalent to the said issue price for the said discount bonds; such issue price shall be referred to as the "issue price, etc. on the final issue date" in Article 26-13(1)(i) and (5)(ii)) from the face value of the said discount bonds and then multiplying the remaining amount after deduction by the rate of income tax on profit from redemption for the said discount bonds collected at the time of issue pursuant to the provisions of Article 41-12(3) of the Act, and where the discount bonds have been redeemed by bringing the redemption date forward or retired by purchase prior to the redemption date, with regard to the remaining amount after deducting the amount to be refunded that was calculated pursuant to the provisions of paragraph (1) of the next Article from the amount of the income tax).In this case, the term "interest" in Article 140-2(1)(i) of the Order for Enforcement of the Corporation Tax Act shall be deemed to be replaced with "profit from redemption"; the term "out of the number of months" in paragraph (2) of the said Article shall be deemed to be replaced with "out of the number of months (the number of days, where the said dividend of interest, etc. is profit from redemption for short-term government or company bonds (meaning short-term government or company bonds prescribed in Article 41-12(9) of the Act on Special Measures Concerning Taxation; the same shall apply in the next paragraph); hereinafter the same shall apply in this paragraph);" and the term "the amount of income prescribed in paragraph (1)(i)" in paragraph (3) of the said Article shall be deemed to be replaced with "the amount of income (excluding the amount of income tax on profit from redemption of short-term government or company bonds) prescribed in paragraph (1)(i)."

(2)The amount of income tax collected pursuant to the provisions of Article 41-12(3) of the Act, where a corporation acquired discount bonds at the time of issue, shall be included in the acquisition costs of the said discount bonds; the amount deemed to be income tax to be collected when receiving the redemption pursuant to the provisions of paragraph (4) of the said Article shall not be included in deductible expenses for calculating the amount of income for a business year including the time of receiving the redemption (where the business year is a consolidated business year prescribed in Article 15-2 of the Corporation Tax Act, for calculating the amount of consolidated income prescribed in Article 2(xviii)-4 of the said Act for the said consolidated business year; hereinafter the same shall apply in this paragraph); and the amount of income tax to be deducted from corporation tax pursuant to the provisions of Article 68 (including the cases where it is applied mutatis mutandis pursuant to Article 144 of the said Act) or Article 81-14 of the said Act shall be included in gross profits for calculating the amount of income that is to be deducted for that business year.

Article 26-12(1)The amount of income tax to be refunded pursuant to the provisions of Article 41-12(5) of the Act shall be the amount obtained by deducting the redemption price (where retirement by purchase is performed, the purchase price) from the face value of the discount bonds set forth in the said paragraph and then multiplying the remaining amount after deduction by the rate of income tax on profit from redemption for the said discount bonds collected at the time of issue, pursuant to the provisions of paragraph (3) of the said Article.

(2)A refund under the provisions of Article 41-12(5) of the Act shall be made at the time of redemption prescribed in the said paragraph.In this case, the said amount to be refunded shall be deducted from the amount payable pursuant to the provisions of paragraph (3) of the said Article or Article 181 or 212 of the Income Tax Act.

Article 26-13(1)The amount of income tax to be refunded pursuant to the provisions of Article 41-12(6) of the Act with regard to discount bonds set forth in the said paragraph shall be the amount specified respectively in the following items for the category of cases listed in the relevant items:

(2)The amount corresponding to the period during which a non-taxable corporation, etc. held the said discount bonds as prescribed in items of the preceding paragraph shall be the amount obtained by multiplying the amount of income tax or remaining amount prescribed in the said items by the ratio of the number of months (where the said discount bonds are short-term government or company bonds prescribed in Article 41-12(9) of the Act, the number of days; hereinafter the same shall apply in this paragraph and paragraph (5)(iii)) up to the redemption date during which the said non-taxable corporation, etc. held the said discount bonds out of the number of months from the issue date (where the date is not clear, the final issue date for the said discount bonds) to the redemption date (including a date for retirement by purchase; hereinafter the same shall apply in this Article) of the said discount bonds.

(3)The number of months set forth in the preceding paragraph shall be calculated by calendar month, and when there are any fractions less than one month, those fractions shall be deemed to be one month for counting the period during which a non-taxable corporation, etc. held the said discount bonds and shall be rounded off for calculating the period from the issue date to the redemption date of the said discount bonds, and when the ratio set forth in the said paragraph exceeds one, the ratio shall be deemed to be one.

(4)A refund pursuant to the provisions of Article 41-12(6) shall be made at the time of paying the profit from redemption prescribed in the said paragraph upon request from a non-taxable corporation, etc.In this case, the provisions of the second sentence of Article 26-12(2) shall apply mutatis mutandis.

(5)A non-taxable corporation, etc. intending to receive a refund pursuant to the provisions of Article 41-12(6) of the Act shall submit a written request for a refund containing the following matters, along with a document certifying the date of acquisition of the discount bonds, to the issuer of the said discount bonds by the day on which he/she receives the payment of the profit from redemption prescribed in the said paragraph for the said discount bonds set forth in the said paragraph:

Article 26-14(1)Where the provisions of Article 26-12(2) or paragraph (4) of the preceding Article shall apply, when there is any amount that an issuer prescribed in Article 41-12(5) or (6) of the Act (hereinafter referred to as an "issuer" in this Article) cannot deduct as prescribed in the second sentence of Article 26-12(2) (including the cases where it is applied mutatis mutandis pursuant to paragraph (4) of the preceding Article) in the month following the month including the day on which he/she shall make a refund pursuant to the provisions of Article 41-12(5) or (6) of the Act, the competent district director having jurisdiction over the place for tax payment prescribed in Article 26-10(2) for income tax pertaining to the profit from redemption for discount bonds prescribed in Article 41-12(5) or (6) of the Act shall refund the said amount that cannot be deducted to the said issuer.

(2)An issuer who seeks the application of the provisions of the preceding paragraph shall submit a document containing that fact to the competent district director set forth in the preceding paragraph, along with a detailed statement containing the amount that he/she shall refund pursuant to the provisions of Article 41-12(5) or (6) of the Act, the amount that he/she cannot deduct as prescribed in the preceding paragraph out of the said amount, which of the provisions of paragraph (5) or paragraph (6) of the said Article the said refund is based on, and other necessary matters.

(3)Where the interest on a refund prescribed in Article 58(1) of the Act on General Rules for National Taxes is to be calculated with regard to a refund under the provisions of paragraph (1), the period set forth in Article 58(1) of the said Act to be used as the basis for the calculation shall be the period from the day on which one month has elapsed from the next day of submitting the documents set forth in the preceding paragraph up to the day on which the payment for the refund is determined or the day on which an appropriation is made for the refund (where there has been any day suitable for an appropriation before such day, up to the day which proved to be suitable).

Article 26-15(1)The government or company bonds specified by a Cabinet Order prescribed in Article 41-12(7) of the Act shall be the government or company bonds listed as follows which are issued by means of a discount:

(2)The bonds specified by a Cabinet Order prescribed in Article 41-12(7)(ii) of the Act shall be the bonds issued by the Japan Housing Finance Agency, the Okinawa Development Finance Corporation, or the Urban Renaissance Agency pursuant to the provisions of Article 8 of the Supplementary Provisions of the Japan Housing Finance Agency Act, Article 27(4) of the Okinawa Development Finance Corporation Act (Act No. 31 of 1972) or Article 15(1) of the Supplementary Provisions of the Urban Renaissance Agency Act.

Article 26-16The entries or records under the book-entry transfer system specified by a Cabinet Order prescribed in Article 41-12(9) of the Act shall be the entries or records under the book-entry transfer system specified respectively in the following items for the category of short-term government or company bonds listed in the relevant items:

Article 26-17The income specified by a Cabinet Order prescribed in Article 41-12(10) of the Act shall be the income from a transfer of specified short-term government or company bonds prescribed in the said paragraph that was carried out by a resident or a non-resident who maintains a permanent establishment in Japan.

Article 26-18(1)The person specified by a Cabinet Order prescribed in Article 41-12(12) of the Act shall be the national government or any of the following:

(2)The documents specified by a Cabinet Order prescribed in Article 41-12(12) of the Act shall be the documents listed respectively in the following items for the category of persons listed in the relevant items:

(3)The identification documents prescribed in Article 41-12(12) of the Act (hereinafter referred to as the "identification documents" through to Article 26-20) shall be presented pursuant to the provisions of Article 41-12(12) of the Act when submitting a written notice set forth in the said paragraph.

(4)When a person who had submitted a written notice set forth in Article 41-12(12) of the Act has changed the person's name or address (or any other place specified by an Ordinance of the Ministry of Finance in the case where the person does not have an address in Japan; hereinafter the same shall apply through to Article 26-20), the person shall promptly submit a document containing the person's name and address after the change to the head of the business office, etc. (meaning a business office, etc. prescribed in Article 41-12(12) of the Act; hereinafter the same shall apply in this Article) of the specified book-entry transfer institution, etc. to which the person had submitted the written notice (where the person had submitted the said written notice, pursuant to the provisions of the said paragraph, via a foreign intermediary to the head of the business office, etc. of the specified book-entry transfer institution, etc. where he/she makes entries or records under the book-entry transfer system for the specified book-entry transfer national government bonds, etc. (meaning specified book-entry transfer national government bonds, etc. prescribed in the said paragraph; hereinafter the same shall apply through to Article 26-20), the person shall promptly submit such document via the said foreign intermediary to the head of the business office, etc. of the said specified book-entry transfer institution, etc., according to the provisions of the first sentence of Article 41-12(12) of the Act).The same shall apply where the person has changed the name or address again after submitting the said document.

(5)A person who submits the document prescribed in the preceding paragraph shall, when submitting the said document, present the identification documents to the head of the business office, etc. of the specified book-entry transfer institution, etc. to which he/she submits the said document (excluding the case where he/she submits the said document via a foreign intermediary; the same shall apply in the next paragraph) or to the head of the overseas business office, etc. (meaning the overseas business office, etc. prescribed in Article 41-12(12) of the Act) of the foreign intermediary set forth in the said paragraph via which he/she had submitted a written notice prescribed in the preceding paragraph as prescribed in Article 41-12(12) of the Act (referred to as the "head of the overseas business office, etc. of the foreign intermediary" in the next paragraph and paragraph (8)).

(6)The head of the business office, etc. of the specified book-entry transfer institution, etc. or the head of the overseas business office, etc. of the foreign intermediary shall, when a written notice prescribed in Article 41-12(12) of the Act or the document prescribed in paragraph (4) has been submitted, confirm whether or not the name and address entered in the said written notice or the document are consistent with the name and address entered in the identification documents which were presented pursuant to the provisions of Article 41-12(12) of the Act or the preceding paragraph at the time of the submission of the said written notice or the document.

(7)The foreign intermediary set forth in the preceding paragraph that has provided a confirmation pursuant to the provisions of the said paragraph shall submit the documents prescribed in Article 41-12(14) of the Act for each person who makes entries or records under the book-entry transfer system set forth in paragraph (12) of the said Article to the head of the business office, etc. of the specified book-entry transfer institution, etc. where the foreign intermediary makes entries or records under the book-entry transfer system for specified book-entry transfer national government bonds, etc. pertaining to the said confirmation (where the said foreign intermediary is a foreign further indirect account management institution (meaning a foreign further indirect account management institution prescribed in the said paragraph), to the head of the business office, etc. of the specified book-entry transfer institution, etc. where the foreign further indirect account management institution prescribed in paragraph (14) of the said Article pertaining to the said specified book-entry transfer national government bonds, etc. makes entries or records under the book-entry transfer system for the said specified book-entry transfer national government bonds, etc. via the said foreign further indirect account management institution).

(8)The head of the business office, etc. of the specified book-entry transfer institution, etc. or the head of the overseas business office, etc. of the foreign intermediary shall, when having provided a confirmation pursuant to the provisions of paragraph (6), clearly record that he/she has provided the said confirmation in the books concerning the said confirmation (including the books or documents equivalent thereto), pursuant to the provisions of an Ordinance of the Ministry of Finance, and preserve the said books; and the head of the business office, etc. of the specified book-entry transfer institution, etc. who has received the submission of a written notice prescribed in Article 41-12(12) of the Act, the document prescribed in paragraph (4) or the documents prescribed in the preceding paragraph shall preserve such written notice and documents, pursuant to the provisions of an Ordinance of the Ministry of Finance.

(9)Where a nonresident or foreign corporation (excluding those listed in paragraph (1)(i), (iii), or (iv); hereinafter the same shall apply in this paragraph) makes entries or records under the book-entry transfer system for short-term national government bonds, etc. (meaning national government bonds listed in Article 41-12(9)(i) to (viii) of the Act which fall under the category of specified short-term government or company bonds and principal-only book-entry transfer national government bonds and coupon-only book-entry transfer national government bonds prescribed in paragraph (12) of the said Article) for the first time on or after April 1, 1999 in the account pertaining to entries or records under the book-entry transfer system that has gone through the confirmation pursuant to the provision of Article 5-2(9) of the Act (including the cases where it is applied mutatis mutandis pursuant to paragraph (12) of the said Article; hereinafter the same shall apply in this paragraph) (hereinafter such confirmation shall be referred to as a "confirmation pertaining to book-entry transfer national government bonds, etc." in this paragraph), with regard to the said entries or records under the book-entry transfer system, it shall be deemed that the submission of a written notice set forth in Article 41-12(12) of the Act under the provisions of the said paragraph (including the submission of the document set forth in paragraph (4) under the provisions of the said paragraph) has been made by the submission of a written application for tax exemption of book-entry transfer national government bonds set forth in Article 5-2(1)(i)(a) of the Act under the provisions of (a) of the said item (including the submission of a written application set forth in paragraph (10) of the said Article under the provisions of the said paragraph) or the submission of a written application for tax exemption of book-entry transfer local government bonds set forth in Article 5(1)(ii)(a) of the Act under the provisions of (a) of the said item (including the submission of a written application set forth in paragraph (11) of the said Article under the provisions of the said paragraph) for the said confirmation pertaining to book-entry transfer national government bonds, etc., that the presentation of the identification documents under the provisions of Article 41-12(12) of the Act (including the provisions of paragraph (5)) has been made by the presentation of the documents specified by a Cabinet Order set forth in Article 5-2(9) of the Act under the provisions of the said paragraph for the said confirmation pertaining to book-entry transfer national government bonds, etc., and that the confirmation under the provisions of paragraph (6) (including the submission of the documents set forth in paragraph (7) under the provisions of the said paragraph) has been provided by the said confirmation pertaining to book-entry transfer national government bonds, etc.; provided, however, that this shall not apply when the name and address to be entered in a written notice set forth in Article 41-12(12) of the Act or the document set forth in paragraph (4) are inconsistent with the name and address of the said nonresident or foreign corporation for which the said confirmation pertaining to book-entry transfer national government bonds, etc. has been provided.

(10)The form of a written notice set forth in Article 41-12(12) of the Act shall be specified by an Ordinance of the Ministry of Finance.

(11)The documents specified by a Cabinet Order prescribed in Article 41-12(14) of the Act shall be a document certifying that the confirmation prescribed in the said paragraph has been provided, the identification documents and a copy of the said identification documents.

Article 26-18-2(1)When persons intending to make entries or records under the book-entry transfer system prescribed in Article 41-12(15) of the Act (hereinafter referred to as "customers" in this Article) have made entries or records under the book-entry transfer system for specified book-entry transfer national government bonds, etc. via a foreign intermediary, the said foreign intermediary shall enter or record the matters prescribed in the said paragraph in the books prescribed in the said paragraph, for each of the said customers each time, and preserve the said books pursuant to the provisions of an Ordinance of the Ministry of Finance.

(2)When customers have made entries or records under the book-entry transfer system for specified book-entry transfer national government bonds, etc. via a foreign intermediary, the said foreign intermediary shall provide information about the matters prescribed in Article 41-12(16) of the Act for each of the said customers to the specified book-entry transfer institution, etc. prescribed in the said paragraph of the said foreign intermediary pertaining to the said specified book-entry transfer national government bonds, etc. by way of a document or any other means prescribed in the next paragraph.

(3)The means specified by a Cabinet Order prescribed in Article 41-12(16) of the Act shall be a means of using an electronic data processing system or another means of using information and communications technology that is specified by an Ordinance of the Ministry of Finance.

(4)The specified book-entry transfer institution, etc. prescribed in paragraph (2) shall, when having received a notification set forth in the said paragraph, enter or record the said matters notified, for each of the customers each time, in the books prescribed in Article 41-12(16) of the Act and preserve the said books pursuant to the provisions of an Ordinance of the Ministry of Finance.

Article 26-19(1)Those specified by a Cabinet Order prescribed in Article 41-12(17) of the Act shall be the national government and those listed in Article 26-18(1)(i), (ii) and (iv) (referred to as "public corporations, etc." in paragraph (1) of the next Article).

(2)A notification under the provisions of Article 41-12(17) of the Act shall be made each time, on receipt of the payment of a consideration for the transfer of specified book-entry transfer national government bonds, etc. prescribed in the said paragraph.

(3)The identification documents shall be presented pursuant to the provisions of Article 41-12(17) of the Act when making a notification set forth in the same paragraph.

(4)Necessary matters concerning the scope of the identification documents that a person intending to make a notification under the provisions of Article 41-12(17) of the Act shall present pursuant to the provisions of the said paragraph shall be specified by an Ordinance of the Ministry of Finance.

(5)A payer prescribed in Article 41-12(17) of the Act (referred to as a "payer" in the next paragraph) shall, when having received a notification under the provisions of paragraph (17) of the said Article, confirm whether or not the name and address notified are consistent with the name and address entered in the identification documents that were presented to him/her at the time of the said notification pursuant to the provisions of the said paragraph.

(6)A payer shall, when having provided a confirmation under the provisions of the preceding paragraph, clearly record that he/she has provided the said confirmation in the books concerning the said confirmation (including the books or documents equivalent thereto), pursuant to the provisions of an Ordinance of the Ministry of Finance, and preserve the said books.

Article 26-20(1)Those specified by a Cabinet Order prescribed in Article 41-12(18) of the Act shall be public corporations, etc.

(2)Where a specified book-entry transfer institution, etc. and a foreign intermediary receive redemption money (meaning redemption money prescribed in Article 41-12(18) of the Act; hereinafter the same shall apply in this Article) or payment of interest (meaning interest prescribed in Article 41-12(18) of the Act; hereinafter the same shall apply in this Article) pertaining to specified book-entry transfer national government bonds, etc., due to the redemption (meaning the redemption prescribed in Article 41-12(18) of the Act; the same shall apply in paragraph (7)) or payment of interest, a written notice set forth in Article 41-12(18) of the Act under the provisions of the said paragraph shall not be required to be submitted for the receipt of the said redemption or payment of interest.

(3)The identification documents shall be presented pursuant to the provisions of Article 41-12(18) of the Act when submitting a written notice set forth in the said paragraph.

(4)Necessary matters concerning the scope of the identification documents that a person intending to submit a written notice under the provisions of Article 41-12(18) of the Act shall present pursuant to the provisions of the said paragraph shall be specified by an Ordinance of the Ministry of Finance.

(5)A person in charge of handling payment of redemption money or interest pertaining to specified book-entry transfer national government bonds, etc. shall, when a written notice prescribed in Article 41-12(18) of the Act has been submitted, confirm whether or not the name and address entered in the said written notice are consistent with the name and address entered in the identification documents that were presented to him/her at the time of the submission of the said written notice pursuant to the provisions of the said paragraph.

(6)A person in charge of handling payment of redemption money or interest pertaining to specified book-entry transfer national government bonds, etc. shall, when having provided a confirmation under the provisions of the preceding paragraph, clearly record that he/she has provided the said confirmation in the books concerning the said confirmation (including the books or documents equivalent thereto), pursuant to the provisions of an Ordinance of the Ministry of Finance, and preserve the said books and the written notice prescribed in Article 41-12(18) of the Act.

(7)Where a person who receives a payment prescribed in Article 41-12(18) of the Act receives redemption money or payment of interest pertaining to specified book-entry transfer national government bonds, etc., due to the redemption or payment of interest, pertaining to a confirmation provided pursuant to the provisions of Article 26-18(6) (hereinafter referred to as a "confirmation pertaining to entries or records under the book-entry transfer system" in this paragraph), with regard to the receipt of the said redemption money or payment of interest, it shall be deemed that the submission of a written notice set forth in Article 41-12(18) of the Act under the provisions of the said paragraph has been made by the submission of a written notice set forth in Article 41-12(12) of the Act under the provisions of the said paragraph (including the submission of the document set forth in Article 26-18(4) under the provisions of the said paragraph) for the said confirmation pertaining to entries or records under the book-entry transfer system, that the presentation of the identification documents under the provisions of Article 41-12(18) of the Act has been made by the presentation of the identification documents under the provisions of Article 41-12(12) of the Act (including the provisions of Article 26-18(5)) for the said confirmation pertaining to entries or records under the book-entry transfer system, and that the confirmation under the provisions of Article 41-12(18) of the Act (including the submission of the documents set forth in paragraph (14) of the said Article under the provisions of the said paragraph which is applied mutatis mutandis pursuant to paragraph (19) of the said Article) has been provided by the said confirmation pertaining to entries or records under the book-entry transfer system; provided, however, that this shall not apply when the name and address to be entered in a written notice set forth in Article 41-12(18) of the Act are inconsistent with the name and address of the person for which the said confirmation pertaining to entries or records under the book-entry transfer system has been provided.

(8)The form of a written notice set forth in Article 41-12(18) of the Act shall be specified by an Ordinance of the Ministry of Finance.

Article 26-21(1)Those specified by a Cabinet Order prescribed in Article 41-12(21) of the Act shall be the national government and those listed in the items of Article 26-18(1).

(2)A payer prescribed in Article 41-12(21) of the Act who intends to obtain the approval set forth in the said paragraph shall submit a written application containing his/her name and location, intention to obtain the said approval, and any other matters specified by an Ordinance of the Ministry of Finance to the competent district director prescribed in the said paragraph.

(3)Where a written application set forth in the preceding paragraph has been submitted, when the competent district director set forth in the said paragraph has granted approval or has decided not to grant approval, he/she shall notify to that effect to the applicant in writing.

(4)A person in charge of handling payment of redemption money or interest pertaining to specified book-entry transfer national government bonds, etc. prescribed in Article 41-12(22) of the Act who intends to obtain the approval set forth in the said paragraph shall submit a written application containing his/her name and location, intention to obtain the said approval, and any other matters specified by an Ordinance of the Ministry of Finance to the competent district director prescribed in the said paragraph.

(5)Where a written application set forth in the preceding paragraph has been submitted, when the competent district director set forth in the said paragraph has granted approval or has decided not to grant approval, he/she shall notify to that effect to the applicant in writing.

(6)A person who pays a consideration for the transfer of specified book-entry transfer national government bonds, etc. or who is in charge of handling payment of redemption money or interest pertaining to specified book-entry transfer national government bonds, etc. prescribed in Article 41-12(23) of the Act, who intends to obtain the approval set forth in the said paragraph, shall submit a written application containing his/her name and location, the type of optical disk prescribed in the said paragraph which he/she intends to submit, and any other matters specified by an Ordinance of the Ministry of Finance to the competent district director having jurisdiction over the said location.

(7)Where a written application set forth in the preceding paragraph has been submitted, when the competent district director set forth in the said paragraph has granted approval or has decided not to grant approval, he/she shall notify to that effect to the applicant in writing.

(8)The form of a report of payment of a consideration for the transfer of specified book-entry transfer national government bonds, etc. prescribed in Article 41-12(21) of the Act or a report of payment of redemption money, etc. of specified book-entry transfer national government bonds, etc. prescribed in paragraph (22) of the said Article shall be specified by an Ordinance of the Ministry of Finance.

Article 26-22The discount on bonds specified by a Cabinet Order prescribed in Article 41-13 of the Act shall be the discount on bonds listed as follows:

Article 27(1)With respect to the place for tax payment of income tax to be collected, pursuant to the provisions of Article 42(1) of the Act, for the payment of the remuneration paid by a tax-exempt entertainment corporation, etc. prescribed in Article 42(1) of the Act (referred to as a "tax-exempt entertainment corporation, etc." in paragraph (3)) to entertainers, etc. for their provision of services, the term "shall be the place prescribed in the said items" in Article 55 of the Order for Enforcement of the Income Tax Act shall be deemed to be replaced with "shall be the place prescribed in the said items (with respect to the remuneration paid by a tax-exempt entertainment corporation, etc. prescribed in Article 42(1) (Special Provisions for Withholding at Source of Remuneration, etc. Paid by Tax-Exempt Entertainment Corporations, etc. to Entertainers for Their Provision of Services) of the Act on Special Measures Concerning Taxation (Act No. 26 of 1957) (hereinafter referred to as a "tax-exempt entertainment corporation, etc." in this Article), outside Japan, to entertainers, etc. listed in the items of the said paragraph for their provision of services out of consideration for the provision of the services of entertainers, etc. prescribed in the said paragraph (hereinafter referred to as the "consideration for the provision of the services of entertainers, etc." in this Article), the location of an office, business office or any other place equivalent thereto located in Japan of a person who pays the consideration for the provision of the services of entertainers, etc. of the said entertainers, etc. to the said tax-exempt entertainment corporation, etc. (where such person falls under the category of a tax-exempt entertainment corporation, etc., a person who pays the consideration for the provision of the services of entertainers, etc. to the said person) (where there are two or more locations, the principal location))."

(2)With respect to the application of the provisions of Article 264 of the Order for Enforcement of the Income Tax Act where the provisions of Article 42(1) of the Act are applied, the term "Article 212(1) (Withholding Liability for Income of Nonresidents or Corporations) of the Act" in the said Article shall be deemed to be replaced with "Article 212(1) (Withholding Liability for Income of Nonresidents or Corporations) of the Act or Article 42(1) (Special Provisions for Withholding at Source of Remuneration, etc. Paid by Tax-Exempt Entertainment Corporations, etc. to Entertainers for Their Provision of Services) of the Act on Special Measures Concerning Taxation."

(3)Where a tax-exempt entertainment corporation, etc. seeks the application of the provisions of Article 179 and Article 213(1) of the Income Tax Act whose terms were replaced under the provisions of Article 42(3) of the Act with respect to the consideration listed in Article 161(ii) of the Income Tax Act, which they shall receive for the provision of the services of entertainers, etc. prescribed in Article 42(1) of the Act, the said tax-exempt entertainment corporation, etc. shall, when receiving payment of the said consideration, submit a document containing the matters specified by an Ordinance of the Ministry of Finance, via a person who pays the said consideration, to the competent district director having jurisdiction over the place for tax payment of the income tax to be collected and paid for the said consideration by the said payer pursuant to the provisions of Article 212 of the Income Tax Act.

Article 27-2(1)The bond transaction with a repurchase or resale agreement specified by a Cabinet Order prescribed in Article 42-2(1) of the Act shall be a bond transaction where the bonds are transferred or purchased under an agreement to repurchase or resell at the agreed prices on the agreed date (or where it is agreed that the date and prices shall be determined after the commencement of the transaction instead of determining the date and prices in advance, at the said prices on the said date agreed after the commencement of the transaction) and are repurchased or resold based on the said agreement.

(2)The requirements specified by a Cabinet Order prescribed in Article 42-2(1) of the Act shall be as follows (where a specified financial institution, etc. prescribed in the said paragraph (hereinafter referred to as a "specified financial institution, etc." in this Article) is the Bank of Japan, the requirements listed in item (i) and item (iii)):

(3)The interest specified by a Cabinet Order prescribed in Article 42-2(1) of the Act shall be the interest to be received by a foreign financial institution, etc. prescribed in the said paragraph on which no income tax shall be imposed pursuant to the provisions of Article 7 of the Act.

(4)The bonds specified by a Cabinet Order prescribed in Article 42-2(1) of the Act shall be any of the bonds listed as follows:

(5)Whether or not a foreign corporation listed in Article 42-2(4)(i)(a) of the Act out of foreign financial institutions, etc. (meaning foreign financial institutions, etc. prescribed in the said item; hereinafter the same shall apply in this Article) falls under the category of a foreign corporation listed in the items of Article 42-2(2) of the Act shall be determined according to its status at the end of the business year immediately prior to the business year including the day on which the said foreign financial institution, etc. intends to submit a written application for tax exemption (meaning a written application for tax exemption prescribed in Article 42-2(5) of the Act; hereinafter the same shall apply in this Article) and the day preceding the day on which the said foreign financial institution, etc. is to receive payment of specified interest (meaning specified interest prescribed in Article 42-2(1) of the Act; hereinafter the same shall apply in this Article) after submitting the said written application for tax exemption.

(6)A foreign financial institution, etc. which seeks the application of the provisions of Article 42-2(1) of the Act shall, when it intends to receive payment of specified interest from a specified financial institution, etc. for the first time, submit a written application for tax exemption to the district director prescribed in Article 42-2(5) of the Act, via an office, business office, or any other establishment equivalent thereto (hereinafter referred to as "offices, etc." in this paragraph and paragraph (10)) of the said specified financial institution, etc. in charge of handling payment of the said specified interest (where payment of the said specified interest is handled at two or more offices, etc. held by the said specified financial institution, etc., via respective offices at the time when payment is handled for the first time respectively) by the day preceding the day on which the said foreign financial institution, etc. is to receive the said specified interest.

(7)A foreign financial institution, etc. which seeks the application of the provisions of Article 42-2(1) of the Act shall, when it has not been entered or recorded separately in the books prescribed in Article 42-2(10) of the Act of a specified financial institution, etc. which pays specified interest to the said foreign financial institution, etc., submit a written application for tax exemption to the district director prescribed in Article 42-2(5) of the Act pursuant to the provisions of the said paragraph.

(8)Where a foreign financial institution, etc. which had previously received the application of the provisions of Article 42-2(1) of the Act has become unable to receive the application of the said provisions based on the provisions of paragraph (2) of the said Article and subsequently seeks the application of the provisions of Article 42-2(1) of the Act again, the said foreign financial institution, etc. shall submit a written application for tax exemption to the district director prescribed in Article 42-2(5) of the Act, by the day preceding the day on which it is to receive the specified interest, in respect of which it seeks the application of the provisions of the said paragraph.

(9)The documents specified by a Cabinet Order prescribed in Article 42-2(7) of the Act shall be any of the foreign corporation's certificate of registered matters of the corporation, receipt for national tax or local tax, certificate of tax payment or any other document specified by an Ordinance of the Ministry of Finance.

(10)A specified financial institution, etc. shall, when it has received a written application for tax exemption or a written application prescribed in Article 42-2(8) of the Act at its offices, etc., submit such written applications to the district director prescribed in Article 42-2(5) of the Act, by the final day of the month following the month involving the date of the receipt, and create copies of such written applications (including those equivalent thereto) and preserve them pursuant to the provisions of an Ordinance of the Ministry of Finance.

(11)In the case referred to in Article 42-2(8) of the Act, when a written application prescribed in the said paragraph has been submitted to the district director prescribed in the said paragraph, it shall be deemed that the submission has been made at the time when the person who pays specified interest set forth in the said paragraph received the written application.

(12)A specified financial institution, etc. shall, when the contract for a bond transaction with a repurchase/resale agreement prescribed in Article 42-2(1) of the Act has been concluded with a foreign financial institution, etc. which had submitted a written application for tax exemption, or when a written application prescribed in paragraph (8) of the said Article has been submitted by a person who had submitted the said written application for tax exemption, enter or record the matters prescribed in paragraph (10) of the said Article in the books for each person each time, and preserve the said books pursuant to the provisions of an Ordinance of the Ministry of Finance.