Japan Inheritance Guide for United Kingdom (英国) Nationals
This guide explains how Japanese inheritance law and tax apply to United Kingdom nationals living in or inheriting property from Japan. There are approximately approx. 19,000 United Kingdom 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.
UK succession law varies by jurisdiction (England & Wales, Scotland, Northern Ireland). No forced heirship in England & Wales.
Renvoi (反致): May Apply
UK law refers movable property to the law of the domicile and immovable property to lex rei sitae. Renvoi may apply.
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 United Kingdom that may provide relief from double taxation.
3. United Kingdom Inheritance Law
- •No forced heirship in England & Wales (complete testamentary freedom)
- •Scotland has 'legal rights' (a form of forced heirship)
- •UK Inheritance Tax: 40% above £325,000 nil-rate band
- •Spouse exemption: unlimited transfers between spouses
Statutory Inheritance:
England & Wales: spouse receives first £322,000 + half remainder, children receive other half. Scotland: different rules with legal rights.
4. Required Documents
Grant of Probate / Letters of Administration
UK court order authorizing estate administration.
Apostille
UK is a Hague Convention member.
Certified Japanese Translation
English documents translated into Japanese.
5. Professional Fees
| Professional | Fee Range |
|---|---|
| Tax Accountant (税理士) | ¥500,000–¥1,500,000 |
| Lawyer (弁護士) | ¥500,000–¥1,500,000 |
| Judicial Scrivener (司法書士) | ¥80,000–¥200,000 |
| Translation | ¥20,000–¥60,000 |
6. Important Notes
- ⚠UK Inheritance Tax is 40% above £325,000
- ⚠Japan-UK tax treaty provides double tax relief
- ⚠English documents are easier for Japanese legal professionals to work with
Need Help with Inheritance in Japan?
Get connected with English-speaking tax professionals experienced in international inheritance cases.
Frequently Asked Questions
Can I be taxed by both Japan and the UK?
Yes, but the Japan-UK Tax Treaty provides foreign tax credits to prevent double taxation.
United Kingdom 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.