Japan Inheritance Guide for Ireland (アイルランド) Nationals
This guide explains how Japanese inheritance law and tax apply to Ireland nationals living in or inheriting property from Japan. There are approximately approx. 2,500 Ireland 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.
Ireland's Succession Act 1965 governs succession. Ireland opted out of the EU Succession Regulation (Brussels IV). Ireland follows common law conflict rules: domicile for movable property, lex rei sitae for immovable property.
Renvoi (反致): May Apply
Ireland follows common law conflict rules: immovable property follows lex rei sitae, movable property follows the law of the decedent's domicile. For real estate in Japan, Irish rules point to Japanese law.
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 Ireland that may provide relief from double taxation.
3. Ireland Inheritance Law
- •No forced heirship in the civil law sense, but surviving spouse has a 'legal right share' (1/3 if children, 1/2 if no children) that cannot be overridden by will
- •Children have no automatic entitlement but can apply under Section 117 of the Succession Act if the parent 'failed in his moral duty'
- •Ireland imposes Capital Acquisitions Tax (CAT) at 33% on inheritance above thresholds
- •Testamentary freedom exists but is limited by spousal legal right share
Statutory Inheritance:
Spouse and children: spouse receives 1/3, children share 2/3 equally. Spouse alone: entire estate. Children alone: equal shares.
4. Required Documents
Grant of Probate / Letters of Administration
Issued by the Irish Probate Office or District Probate Registry.
Birth/Marriage/Death Certificate
Irish civil registration certificates from the General Register Office.
Apostille
Ireland is a Hague Convention member. Apostille from the Department of Foreign Affairs.
Certified Japanese Translation
English-language documents translated into Japanese.
5. Professional Fees
| Professional | Fee Range |
|---|---|
| Tax Accountant (税理士) | ¥400,000–¥1,200,000 |
| Lawyer (弁護士) | ¥400,000–¥800,000 |
| Judicial Scrivener (司法書士) | ¥80,000–¥200,000 |
| Translation | ¥20,000–¥50,000 |
6. Important Notes
- ⚠Ireland imposes Capital Acquisitions Tax (CAT) at 33% with thresholds: Group A (children) €335,000, Group B (siblings/nieces/nephews) €32,500, Group C (others) €16,250
- ⚠The Japan-Ireland tax treaty provides double taxation relief
- ⚠Ireland opted out of the EU Succession Regulation (Brussels IV)
- ⚠Japan and Ireland have a social security agreement
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Frequently Asked Questions
Does Ireland have inheritance tax?
Yes. Ireland imposes Capital Acquisitions Tax (CAT) at 33% on inheritance exceeding thresholds. Children have a €335,000 threshold. The Japan-Ireland tax treaty helps avoid double taxation.
Does Ireland have forced heirship?
Not in the civil law sense, but the surviving spouse has an absolute 'legal right share' (1/3 with children, 1/2 without) that cannot be overridden by will. Children can also claim under Section 117 if the parent failed in moral duty to provide for them.
Is English documentation from Ireland accepted?
Yes. Irish documents are in English, which simplifies the process. Apostille and certified Japanese translation are still required, but translation costs are lower than for non-English documents.
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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.