Japan Inheritance Guide for Indonesia (インドネシア) Nationals
This guide explains how Japanese inheritance law and tax apply to Indonesia nationals living in or inheriting property from Japan. There are approximately approx. 83,000 Indonesia nationals residing in Japan.
1. Applicable Law (準拠法)
Under Japan's Act on General Rules for Application of Laws (法の適用に関する通則法, Article 36), the inheritance of a person is governed by the national law of the decedent.
Indonesia has a pluralistic legal system for inheritance: Civil Code (BW) for some, Customary Law (Adat) for others, and Islamic Law for Muslims.
Renvoi (反致): Generally Does Not Apply
Indonesian private international law does not clearly recognize renvoi. The applicable inheritance law depends on the decedent's ethnic/religious background.
2. Tax Obligation Type (課税範囲)
Unlimited Taxpayer
Taxed on all worldwide assets.
Applies if: domiciled in Japan, OR foreign national with residence visa who has lived in Japan for 10+ years.
Limited Taxpayer
Taxed only on assets in Japan.
Applies if: not domiciled in Japan, OR foreign national who has lived in Japan for less than 10 years.
Japan has a tax treaty with Indonesia that may provide relief from double taxation.
3. Indonesia Inheritance Law
- •Three parallel inheritance systems: Civil Code, Adat, Islamic
- •For Muslims: Islamic inheritance law (Faraid) applies
- •Male heirs may receive double the share of female heirs under Islamic law
- •No inheritance tax in Indonesia
Statutory Inheritance:
Varies by system. Under Civil Code: spouse and children inherit equally. Under Islamic law: specific fractional shares prescribed by Quran.
4. Required Documents
Family Card (Kartu Keluarga)
Indonesian household registration document.
Indonesian Embassy Authentication
Indonesia is not yet a Hague Apostille member. Consular legalization required.
Certified Japanese Translation
Indonesian documents translated into Japanese.
Letter of Inheritance (Surat Keterangan Ahli Waris)
Official Indonesian document identifying heirs.
5. Professional Fees
| Professional | Fee Range |
|---|---|
| Tax Accountant (税理士) | ¥300,000–¥800,000 |
| Lawyer (弁護士) | ¥300,000–¥800,000 |
| Judicial Scrivener (司法書士) | ¥80,000–¥200,000 |
| Translation & Authentication | ¥50,000–¥200,000 |
6. Important Notes
- ⚠Which Indonesian law applies depends on the decedent's religion and ethnic group
- ⚠Indonesia does not have inheritance tax
- ⚠Consular legalization (not Apostille) is required for Indonesian documents
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Frequently Asked Questions
Which Indonesian law applies to succession?
It depends on the decedent's religion and ethnic background. Muslims follow Islamic inheritance law (Faraid), while others may follow the Civil Code or Customary Law (Adat).
Indonesia Guides by City
Guides for Other Nationalities
This tool provides rough estimates only. It does not constitute tax advice or tax filing services. Actual tax obligations may differ significantly. Please consult a licensed tax professional (税理士) for accurate calculations.