1 Exemption for the full inclusion (1) Specified CFCs (i.e. Cash Box, Paper Company and Black-List Company) : effective tax rate of a CFC greater than or equal to 30% (2) Other CFCs : effective tax rate of a CFC greater than or equal to 20% 2 Exemption for the passive income inclusion (1) Effective tax rate of a CFC greater than or equal to 20% (2) Either passive income less than or equal to JPY 20 million, or passive income per profits before tax ratio less than or equal to 5%