Japan Inheritance Guide for Turkey (トルコ) Nationals
This guide explains how Japanese inheritance law and tax apply to Turkey nationals living in or inheriting property from Japan. There are approximately approx. 6,000 Turkey 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.
Turkish Civil Code (Türk Medeni Kanunu) governs succession. Turkey follows the nationality principle under its International Private and Procedural Law (MÖHUK). Immovable property may follow lex rei sitae.
Renvoi (反致): May Apply
Turkey recognizes renvoi under MÖHUK. For immovable property in Japan, Turkish conflict rules point to lex rei sitae, resulting in renvoi 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.
Japan has a tax treaty with Turkey that may provide relief from double taxation.
3. Turkey Inheritance Law
- •Forced heirship (saklı pay): children receive 1/2, parents 1/4, and surviving spouse 1/4 of the estate as reserved shares
- •Surviving spouse's statutory share varies: 1/4 with children, 1/2 with parents, 3/4 with grandparents, all if no relatives
- •Turkey imposes inheritance tax (veraset ve intikal vergisi) at progressive rates from 1% to 30%
- •Matrimonial property regime: participation in acquired property (edinilmiş mallara katılma) is the default since 2002
Statutory Inheritance:
Children and spouse are first-order heirs. Spouse receives 1/4 alongside children. Children share the remaining 3/4 equally.
4. Required Documents
Veraset İlamı (Certificate of Inheritance)
Turkish court-issued certificate of heirship, obtained from the Sulh Hukuk Mahkemesi (civil court of peace).
Nüfus Kayıt Örneği (Civil Registry Record)
Turkish population registry extract showing family relationships.
Apostille
Turkey is a Hague Convention member. Apostille from the Valilik (governor's office) or court.
Certified Japanese Translation
All Turkish-language documents must be translated into Japanese by a certified translator.
5. Professional Fees
| Professional | Fee Range |
|---|---|
| Tax Accountant (税理士) | ¥400,000–¥1,200,000 |
| Lawyer (弁護士) | ¥400,000–¥800,000 |
| Judicial Scrivener (司法書士) | ¥80,000–¥200,000 |
| Translation & Apostille | ¥60,000–¥150,000 |
6. Important Notes
- ⚠Turkey imposes inheritance tax at 1–30%; the Japan-Turkey tax treaty provides double taxation relief
- ⚠Turkish forced heirship shares differ from Japanese 遺留分; applicable law determines which system applies
- ⚠Turkey joined the Hague Apostille Convention in 1985
- ⚠Religious marriage alone is not legally recognized in Turkey for inheritance purposes; civil marriage is required
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Frequently Asked Questions
Does Turkey have inheritance tax?
Yes. Turkey imposes veraset ve intikal vergisi at rates from 1% to 30%. Exemptions apply for small estates. The Japan-Turkey tax treaty helps avoid double taxation.
Which law applies to a Turkish national who dies in Japan?
Under Japan's conflict of laws rules, Turkish law applies as the national law. Turkish private international law may refer immovable property back to lex rei sitae, resulting in renvoi to Japanese law for real estate in Japan.
Is a Turkish Veraset İlamı accepted in Japan?
Yes, with Apostille and certified Japanese translation. The Veraset İlamı from a Turkish court serves as proof of heir status for Japanese 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.