Japan Inheritance Guide for Iran (イラン) Nationals
This guide explains how Japanese inheritance law and tax apply to Iran nationals living in or inheriting property from Japan. There are approximately approx. 4,500 Iran 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.
Iranian Civil Code governs succession, heavily based on Shia Islamic law (Jafari jurisprudence). Iran applies the nationality principle: Iranian law follows the decedent regardless of location.
Renvoi (反致): Generally Does Not Apply
Iran strongly adheres to the nationality principle and generally does not accept renvoi. Iranian law insists on applying to all Iranian nationals regardless of domicile or asset location.
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.
3. Iran Inheritance Law
- •Mandatory Islamic inheritance shares (Shia Jafari): specific fractions prescribed by the Quran and Hadith
- •Daughters receive half the share of sons; wife receives 1/8 if there are children, 1/4 if none
- •Non-Muslim heirs cannot inherit from a Muslim decedent under Iranian law
- •Iran does not impose inheritance tax (abolished; transfer tax of 7.5–65% on real estate applies)
Statutory Inheritance:
Shia Islamic shares: wife receives 1/8 (with children) or 1/4 (without). Sons receive double the share of daughters. Parents each receive 1/6 if there are children.
4. Required Documents
Shenasnameh (Birth Certificate / ID Book)
Iranian identity booklet containing family information and civil status.
Iranian Court Inheritance Certificate
Certificate of heirship issued by an Iranian court (Shoray-e Hal-e Ekhtelaf).
Consular Authentication
Iran is NOT a Hague Apostille Convention member. Documents require authentication through the Iranian consulate/embassy.
Certified Japanese Translation
All Farsi-language documents must be translated into Japanese by a certified translator.
5. Professional Fees
| Professional | Fee Range |
|---|---|
| Tax Accountant (税理士) | ¥300,000–¥1,000,000 |
| Lawyer (弁護士) | ¥500,000–¥1,000,000 |
| Judicial Scrivener (司法書士) | ¥80,000–¥200,000 |
| Translation & Authentication | ¥80,000–¥200,000 |
6. Important Notes
- ⚠Iranian inheritance law is based on Shia Islamic law and prescribes unequal shares between genders
- ⚠Iran does not recognize dual nationality; all persons born to Iranian fathers are considered Iranian
- ⚠Iran is NOT a member of the Hague Apostille Convention; consular legalization is required
- ⚠Japan and Iran do not have a tax treaty or social security agreement
Need Help with Inheritance in Japan?
Get connected with English-speaking tax professionals experienced in international inheritance cases.
Frequently Asked Questions
Does Iran have inheritance tax?
Iran does not have a traditional inheritance tax, but imposes a transfer tax on inherited real estate at rates of 7.5% to 65% depending on the relationship. Japanese inheritance tax applies separately.
Does Iranian Islamic law apply to inheritance in Japan?
Under Japan's conflict of laws rules (Article 36), the decedent's national law applies. For Iranian nationals, this means Shia Islamic inheritance law governs. However, Japanese courts may refuse to apply provisions that violate Japanese public policy (公序良俗).
Can gender-based inheritance shares under Iranian law be challenged in Japan?
Japanese courts may invoke the public policy exception (通則法42条) if the result of applying Iranian law is manifestly incompatible with Japanese public order. However, this is applied on a case-by-case basis and is not automatic.
Iran 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.