【Relevant regulations】
Corporation tax Act.
Subsection 3 Calculation of Amount of Gross Revenue
Division 1 Amount of Revenue
Article 22-2. The amount of revenue from the sale or transfer of assets or provision of services (hereinafter referred to as “sale of assets, etc.” in this Article) conducted by a domestic corporation shall be, unless otherwise provided (excluding paragraph (4) of the preceding Article), included in the amount of gross revenue in the calculation of taxable income for the accounting period in which the day of the delivery of the object or the provision of services involved in the sale of assets, etc. falls.
(2) Where a domestic corporation has recognized the amount of revenue from the sale of assets, etc. as revenue in its settlement of accounts that has been determined for the accounting period including a day that is near the day prescribed in the preceding paragraph such as the day on which a contract related to the said sale of assets, etc. becomes effective in accordance with accounting standards generally accepted as fair and appropriate, the amount of revenue from the said sale of asset, etc. shall be, unless otherwise provided (excluding paragraph (4) of the preceding Article), included in the amount of gross revenue in the calculation of the amount of taxable income for the said accounting period, notwithstanding the provisions of the preceding paragraph.
(3) Where a domestic corporation has conducted sale of assets, etc. (excluding the case where a domestic corporation has recognized the amount of revenue from the said sale of assets, etc. as revenue in its settlement of accounts that has been determined for the accounting period including the day prescribed in paragraph (1) or the day that is near that day as prescribed in the preceding paragraph in accordance with accounting standards generally accepted as fair and appropriate), if the tax return filed for the accounting period including the day that is near as prescribed in the said paragraph regarding the said sale of assets, etc. contains a statement concerning the inclusion in gross revenue of the amount of revenue from the said sale of assets, etc., the domestic corporation shall be deemed to have recognized the said amount as revenue in its settlement of accounts that has been determined for the said accounting period, and the provisions of the said paragraph shall apply thereto.
(4) The amount to be included in the amount of gross revenue as the amount of revenue from the sale of assets, etc. for each accounting period of a domestic corporation in the calculation of the amount of taxable income for the said accounting period pursuant to the provisions of paragraph (1) or (2) shall be, unless otherwise provided (excluding paragraph (4) of the preceding Article), an amount equivalent to the value of the assets sold or transferred as of the time of delivery thereof or the amount of consideration to be normally obtained for the services provided.
Basic circular for Corporation tax act
(General Rules for Value, etc. at the Time of Delivery of Assets)
2-1-1-10 Corporation tax act Article 22-2 Paragraph 4 <<Amount of Income>> “an amount equivalent to the value of the assets sold or transferred as of the time of delivery thereof or the amount of consideration to be normally obtained for the services provided” (hereinafter referred to as “the value at the time of delivery, etc.” up to 11 of 2-1-1) is, in principle, usually the price at which transactions are made between third parties for the sale of assets, etc. say the price.
In addition, if there is no agreement on the amount of consideration by the end of the business year that includes the date of delivery of the assets or provision of services related to the sale of assets, etc., the price at the time of delivery will be appropriate based on the current situation on that day.