Japan Inheritance Guide for Sweden (スウェーデン) Nationals
This guide explains how Japanese inheritance law and tax apply to Sweden nationals living in or inheriting property from Japan. There are approximately approx. 2,000 Sweden 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.
Swedish Inheritance Code (Ärvdabalk, 1958) governs succession. Sweden opted out of the EU Succession Regulation (Brussels IV) along with Denmark and Ireland. Sweden traditionally follows the domicile principle for conflict of laws.
Renvoi (反致): May Apply
Swedish conflict of laws rules apply the law of the decedent's domicile for movable property and lex rei sitae for immovable property. For immovable property in Japan, Swedish rules point to Japanese law, resulting in renvoi.
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 Sweden that may provide relief from double taxation.
3. Sweden Inheritance Law
- •Forced heirship (laglott): children receive at least 1/2 of their statutory share (laglott = 1/2 of arvslott)
- •Surviving spouse has a strong position: right to retain joint property up to 4 prisbasbelopp (price base amounts)
- •Sweden abolished inheritance tax (arvsskatt) in 2005
- •Deferred inheritance: children's inheritance may be deferred until the surviving spouse's death (efterarv)
Statutory Inheritance:
Children inherit equally. Surviving spouse inherits ahead of children from the same marriage (deferred inheritance). Children from other relationships inherit immediately.
4. Required Documents
Bouppteckning (Estate Inventory)
Swedish estate inventory document registered with the Swedish Tax Agency (Skatteverket).
Personbevis (Personal Certificate)
Swedish population register extract showing family relationships.
Apostille
Sweden is a Hague Convention member. Apostille from Notarius Publicus.
Certified Japanese Translation
Swedish-language documents translated into Japanese.
5. Professional Fees
| Professional | Fee Range |
|---|---|
| Tax Accountant (税理士) | ¥300,000–¥800,000 |
| Lawyer (弁護士) | ¥300,000–¥600,000 |
| Judicial Scrivener (司法書士) | ¥80,000–¥200,000 |
| Translation & Apostille | ¥50,000–¥130,000 |
6. Important Notes
- ⚠Sweden abolished inheritance tax in 2005; only Japanese inheritance tax applies
- ⚠The Japan-Sweden tax treaty provides double taxation relief for income/corporate taxes
- ⚠Sweden opted out of the EU Succession Regulation (Brussels IV)
- ⚠Japan and Sweden have a social security agreement
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Frequently Asked Questions
Does Sweden have inheritance tax?
No. Sweden abolished inheritance tax (arvsskatt) in 2005. Only Japanese inheritance tax applies to assets in Japan.
What is efterarv (deferred inheritance)?
Under Swedish law, if the decedent is survived by a spouse, children from the same marriage must wait to receive their inheritance until the surviving spouse dies. This is called efterarv (deferred inheritance). Children from other relationships inherit immediately.
Which law applies — Swedish or Japanese?
Under Japan's conflict of laws, Swedish law applies as the national law. Swedish conflict rules apply lex rei sitae for immovable property in Japan, resulting in renvoi to Japanese law for real estate.
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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.