Japan Inheritance Guide for Nigeria (ナイジェリア) Nationals
This guide explains how Japanese inheritance law and tax apply to Nigeria nationals living in or inheriting property from Japan. There are approximately approx. 4,500 Nigeria 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.
Nigerian succession law varies by region and personal law. Southern Nigeria follows English common law. Northern Nigeria applies Sharia law for Muslims. Customary law applies in many communities. The Wills Act (applicable in Lagos and other states) governs testamentary succession.
Renvoi (反致): May Apply
Nigeria follows common law conflict rules: immovable property follows lex rei sitae, movable property follows the law of the decedent's domicile. For property in Japan, Nigerian 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.
3. Nigeria Inheritance Law
- •No unified federal inheritance law; varies by state, religion, and customary law
- •Under common law (Southern Nigeria): testamentary freedom, no forced heirship
- •Under Islamic law (Northern Nigeria): Quranic shares (faraid) apply as mandatory distribution
- •Nigeria does not impose a national inheritance tax
Statutory Inheritance:
Under common law (applicable in Lagos): spouse and children share the estate. Under Islamic law: specific Quranic shares apply (e.g., wife receives 1/8 if there are children).
4. Required Documents
Letters of Administration / Grant of Probate
Issued by a Nigerian High Court for intestate or testate succession.
National Identity Document
Nigerian National ID card, international passport, or voter's card.
Consular Authentication
Nigeria is not a Hague Apostille Convention member. Consular legalization through the Nigerian Embassy is required.
Certified Japanese Translation
English-language Nigerian 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 & Authentication | ¥50,000–¥150,000 |
6. Important Notes
- ⚠Nigeria does not have a national inheritance tax; only Japanese inheritance tax applies
- ⚠The applicable Nigerian law depends on the decedent's state of origin, religion, and customary law
- ⚠Nigeria is NOT a Hague Apostille Convention member; consular legalization is required
- ⚠Japan and Nigeria do not have a tax treaty or social security agreement
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Frequently Asked Questions
Does Nigeria have inheritance tax?
No national inheritance tax exists in Nigeria. However, some states may impose estate-related charges. Japanese inheritance tax applies fully to Japan-located assets.
Which Nigerian law applies — common law, Islamic law, or customary law?
It depends on the decedent's personal circumstances: state of origin, religion, and the type of marriage. Southern states generally follow common law, Northern states may apply Islamic law, and customary law applies in many communities.
Can Nigerian documents be Apostilled?
No. Nigeria has not joined the Hague Apostille Convention. Documents must be legalized through the Nigerian Embassy/Consulate in Japan, which takes additional time and cost.
Nigeria 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.