Income Tax Act Article 24-2

Articles 4-1 and 4-2 shall not apply to gains or losses resulting from the buying or selling of securities or financial derivatives as approved by the competent authority for the purposes of risk management undertaken by a warrant issuer who issues call (put) warrants which have been approved by the competent authority. In such case, the gains or losses shall be included in the profits or losses from issuing call (put) warrants. Where, however, the losses resulting from the buying and selling of call (put) warrants and the underlying securities as approved by the competent authority and from the buying and selling of futures, which are subject to the futures transaction tax in accordance with the Futures Transaction Tax Act, exceed the net amount of premiums received for the issuance of the call (put) warrants after subtracting relevant costs and expenses, such losses shall not be deductible.Articles 4-1 and 4-2 shall not apply to profits or losses resulting from the carrying on of the business of financial derivatives transactions as approved by the competent authority. Such profits or losses shall, after the completion of settlement, be included in the amount of the income of the profit-seeking enterprise in the year of settlement and taxed accordingly.