Japan Inheritance Guide for Israel (イスラエル) Nationals
This guide explains how Japanese inheritance law and tax apply to Israel nationals living in or inheriting property from Japan. There are approximately approx. 1,500 Israel 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.
Israel's Succession Law (1965) governs inheritance. Israel follows a secular succession law system separate from religious personal status laws, though religious courts may have parallel jurisdiction for certain communities.
Renvoi (反致): May Apply
Israeli private international law may refer to the law of the decedent's domicile or lex rei sitae for immovable property. For real estate in Japan, renvoi to Japanese law is possible.
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 Israel that may provide relief from double taxation.
3. Israel Inheritance Law
- •Forced heirship exists: the surviving spouse is entitled to certain mandatory rights including residence and maintenance
- •Children and spouse are primary heirs; the law prescribes specific shares
- •Israel does not impose inheritance or estate tax (abolished in 1981)
- •Testamentary freedom is broad but subject to the spouse's maintenance rights
Statutory Inheritance:
Spouse receives the marital dwelling, car, and chattels, plus 1/2 of the remaining estate. Children share the other 1/2 equally.
4. Required Documents
Probate Order / Inheritance Order
Issued by the Israeli Registrar of Inheritance or Family Court.
Teudat Zehut (ID Card)
Israeli national identity document.
Apostille
Israel is a Hague Convention member. Apostille from the Ministry of Foreign Affairs or District Court.
Certified Japanese Translation
Hebrew/English documents translated into Japanese.
5. Professional Fees
| Professional | Fee Range |
|---|---|
| Tax Accountant (税理士) | ¥300,000–¥800,000 |
| Lawyer (弁護士) | ¥400,000–¥800,000 |
| Judicial Scrivener (司法書士) | ¥80,000–¥200,000 |
| Translation & Apostille | ¥50,000–¥150,000 |
6. Important Notes
- ⚠Israel abolished inheritance tax in 1981; only Japanese inheritance tax applies
- ⚠The Japan-Israel tax treaty provides double taxation relief for income taxes
- ⚠Israeli inheritance law is secular, unlike many Middle Eastern countries
- ⚠Religious courts (Rabbinical, Sharia, Christian) may have jurisdiction over certain matters but the secular Succession Law generally prevails
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Frequently Asked Questions
Does Israel have inheritance tax?
No. Israel abolished inheritance and estate taxes in 1981. Only Japanese inheritance tax applies to assets in Japan.
Is Israeli inheritance law secular or religious?
Israel's Succession Law (1965) is secular and applies to all citizens regardless of religion. Religious courts may have parallel jurisdiction for certain matters, but the secular law generally governs inheritance.
Which law applies to an Israeli national in Japan?
Under Japan's conflict of laws, Israeli law applies as the national law. For immovable property in Japan, Israeli conflict rules may refer to lex rei sitae, resulting in renvoi to Japanese law.
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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.