Japan Inheritance Guide for Russia (ロシア) Nationals
This guide explains how Japanese inheritance law and tax apply to Russia nationals living in or inheriting property from Japan. There are approximately approx. 9,000 Russia 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.
The Civil Code of Russia (Part III, Section V) governs succession. Russia follows the scission principle: movable property follows the law of the decedent's last place of residence, and immovable property follows lex rei sitae.
Renvoi (反致): May Apply
Russian private international law (Article 1190 of the Civil Code) recognizes renvoi. For immovable property in Japan, Russian conflict rules point to Japanese law. For movable property, if the decedent resided in Japan, Japanese law applies.
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 Russia that may provide relief from double taxation.
3. Russia Inheritance Law
- •Forced heirship (обязательная доля): minor children, disabled spouse, and disabled parents receive at least 1/2 of their statutory share
- •Eight priority orders of heirs, with spouse and children in the first order
- •Russia does not impose inheritance tax (abolished in 2006)
- •Community property (совместная собственность) is the default matrimonial regime
Statutory Inheritance:
First order: spouse, children, and parents inherit in equal shares. Spouse first separates their 1/2 community property share.
4. Required Documents
Certificate of Inheritance (Свидетельство о праве на наследство)
Issued by a Russian notary, confirming heir status and shares.
Civil Registry Documents
Russian birth, marriage, and death certificates from ZAGS (civil registry office).
Consular Authentication
Russia is a Hague Convention member (since 1992). Apostille can be obtained from the Ministry of Justice or courts.
Certified Japanese Translation
All Russian-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) | ¥400,000–¥800,000 |
| Judicial Scrivener (司法書士) | ¥80,000–¥200,000 |
| Translation & Authentication | ¥80,000–¥200,000 |
6. Important Notes
- ⚠Russia abolished inheritance tax in 2006; only Japanese inheritance tax applies for Japan-located assets
- ⚠The Japan-Russia tax treaty covers income and corporate taxes but provides limited relief for inheritance
- ⚠Russian documents in Cyrillic require certified translation, which can be more expensive than Western languages
- ⚠Russia's 6-month acceptance period differs from Japan's 3-month period for renunciation
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Frequently Asked Questions
Does Russia have inheritance tax?
No. Russia abolished inheritance tax in 2006. However, Japanese inheritance tax applies fully to assets located in Japan and worldwide assets for unlimited taxpayers.
Which law applies to a Russian national who dies in Japan?
Under Japan's Act on General Rules for Application of Laws (Article 36), Russian law applies as the national law. However, Russian conflict rules refer immovable property to lex rei sitae and movable property to the last residence, so renvoi to Japanese law is likely for property in Japan.
How long do heirs have to accept inheritance under Russian law?
Under Russian law, heirs have 6 months from the date of death to accept inheritance. In Japan, heirs have 3 months to decide whether to accept or renounce. The shorter Japanese deadline should be observed for Japan-related procedures.
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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.