Japan Inheritance Guide for Saudi Arabia (サウジアラビア) Nationals
This guide explains how Japanese inheritance law and tax apply to Saudi Arabia nationals living in or inheriting property from Japan. There are approximately approx. 1,500 Saudi Arabia 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.
Saudi Arabia applies Islamic law (Sharia) based on the Hanbali school of jurisprudence. There is no codified civil code; courts apply Sharia directly. Saudi conflict of laws rules apply the national law of the decedent.
Renvoi (反致): Generally Does Not Apply
Saudi Arabia strictly applies Islamic law to succession of Muslim nationals and does not recognize renvoi. Sharia inheritance shares are considered mandatory and non-derogable.
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 Saudi Arabia that may provide relief from double taxation.
3. Saudi Arabia Inheritance Law
- •Mandatory Islamic inheritance shares (faraid): Quranic fractions prescribe exact shares for each category of heir
- •Testamentary disposition (wasiyya) limited to 1/3 of the estate and cannot benefit a Quranic heir without unanimous consent of other heirs
- •Non-Muslim heirs cannot inherit from a Muslim decedent under Saudi law
- •Saudi Arabia does not impose inheritance tax
Statutory Inheritance:
Sharia inheritance: wife receives 1/8 (with children) or 1/4 (without). Sons receive double the share of daughters. Parents each receive 1/6 when there are children.
4. Required Documents
Sak Hasr Warathah (Certificate of Heirs)
Saudi court-issued certificate listing all legal heirs and their Sharia shares.
Family Register / National ID
Saudi family registration document or national ID card.
Consular Authentication
Saudi Arabia is NOT a Hague Apostille Convention member. Documents require authentication through the Saudi Embassy/Consulate and MOFA.
Certified Japanese Translation
All Arabic-language documents must be translated into Japanese.
5. Professional Fees
| Professional | Fee Range |
|---|---|
| Tax Accountant (税理士) | ¥300,000–¥800,000 |
| 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
- ⚠Saudi Arabia does not impose inheritance tax; only Japanese inheritance tax applies
- ⚠The Japan-Saudi Arabia tax treaty provides income tax relief but does not cover inheritance
- ⚠Saudi Arabia is NOT a Hague Apostille Convention member; consular legalization is required
- ⚠Islamic inheritance law under the Hanbali school is strictly applied; gender-based distribution is mandatory
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Frequently Asked Questions
Does Saudi Arabia have inheritance tax?
No. Saudi Arabia does not impose inheritance tax. Only Japanese inheritance tax applies to assets in Japan.
Can a will override Islamic inheritance shares?
Under Saudi law, a wasiyya (testamentary bequest) is limited to 1/3 of the estate and cannot benefit a Quranic heir without unanimous consent of other heirs. Sharia shares are mandatory.
What happens if a non-Muslim heir exists?
Under Saudi Islamic law, non-Muslims cannot inherit from a Muslim. Japanese courts may apply the public policy exception (公序良俗) if this result is considered manifestly incompatible with Japanese public order.
Saudi Arabia 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.