Overseas Assets Report in Japan: ¥50M Threshold and Deadline

The Overseas Assets Report (国外財産調書) is a form that residents must file with the tax office by 30 June of the following year if the total value of their overseas assets exceeds ¥50 million on 31 December of that year. Non-permanent residents are excluded. Foreign owners living in Japan may become subject to the report as their stay gets longer.

This article sets out the eligibility test and filing steps based on the National Tax Agency (NTA) guidance (Tax Answer No. 7456 and the Q&A). Amounts and deadlines may be revised, so always check the latest NTA guidance before filing.

Who must file the Overseas Assets Report

You must file if you meet both of the following conditions:

• You are a resident of Japan (other than a non-permanent resident)
• The total value of your overseas assets exceeds ¥50 million on 31 December of that year

Under the Income Tax Act, a “resident” is an individual who has a domicile in Japan, or who has had a residence in Japan continuously for one year or more up to the present. Residency is determined based on your circumstances on 31 December of that year. For more detail, see our guide to determining tax residency in Japan. Confirm your residency status first.

Non-permanent residents are excluded: testing foreign-national owners

A non-permanent resident (非永住者) is a resident who meets both of the following conditions:

• Does not hold Japanese nationality
• Had a domicile or residence in Japan for a total of five years or less within the past 10 years

While both conditions apply, there is no obligation to file the Overseas Assets Report. If you are not a Japanese national, you cease to be a non-permanent resident once the above period exceeds five years. If you hold significant overseas assets, the report may apply from that year.

Japanese nationals are not non-permanent residents regardless of how long they stay. Check both your nationality and your period of stay.

Points to check when establishing your period of stay

The test is based on the total period of domicile or residence in Japan within the past 10 years. Distinguishing between domicile and residence can be difficult in some cases. Keep your immigration entry and exit records and resident registration history on hand, and check with a certified tax accountant.

Testing whether assets exceed ¥50 million

The test totals the value of your overseas assets as of 31 December. It is not based on the highest balance held during the year. If your assets are ¥50 million or less on the reference date, the report does not apply for that year.

In practice, the following preparation helps you stay on track:

• Create a list of your overseas deposits, securities, real estate and insurance policies
• Confirm your conversion method for foreign-currency assets, since the test is based on yen values
• Check whether jointly held or company-held assets count as your own holdings
• Confirm valuation methods and the rules for determining where assets are located in the NTA guidance

Treatment may differ if you hold assets through an overseas company. When considering an asset management company, keep personal and corporate holdings separate in your analysis.

Deadline and filing method

The deadline is 30 June of the following year. The NTA Q&A indicates that the deadline for the 2025 tax year (Reiwa 7) is 30 June 2026 (Tuesday). Check the NTA guidance for deadlines for other years.

File with the tax office that has jurisdiction over your income tax place of filing. If you have no income tax liability, file with the office covering your place of residence. If you have no domicile in Japan, file with the office covering your place of residence in Japan.

Forms and filing methods may change with revisions to the rules. Check the latest NTA guidance before filing.

Filing status, surcharges and penalties

The Overseas Assets Report does not by itself determine your tax liability. However, if there is unreported income relating to overseas assets, the surcharge treatment can differ depending on whether the report was filed.

Check the NTA guidance for the reduction and increase rates, applicable taxes, and how incomplete reporting is judged. Failure to file or false reporting is subject to penalties. If your assets may exceed the threshold, file accurately and on time.

Points to note when inheriting overseas assets

Overseas assets acquired through inheritance are also tested as assets held on 31 December. How they relate to the deceased’s assets and the timing of the inheritance requires case-by-case review. For how inheritance and gift tax liability is categorized, see our guide to inheritance and gift tax for foreigners.

Differences from the Statement of Property and Liabilities

The Statement of Property and Liabilities (財産債務調書) is a separate system with a similar name. It covers different assets, has different threshold amounts, and requires different information.

If you may be subject to both, you need to test each one separately. The thresholds and deadlines for the Statement of Property and Liabilities may change, so always check the latest NTA guidance.

Practical checklist before the reference date

1. Confirm whether you are a resident or a non-permanent resident.
2. Create a list of overseas bank accounts, securities, real estate and insurance policies.
3. Arrange to obtain balance records as of 31 December from each financial institution.
4. Agree with your tax accountant on the conversion method for foreign-currency assets.
5. Check for any overseas assets acquired through inheritance or gift.
6. Plan your work so that you can meet the deadline the following year.

Overseas bank balance certificates can take time to obtain. Requesting them early in the new year leaves more room before the deadline.

What to prepare

The report requires the type, quantity and value of each asset. The following documents will help you prepare:

• Balance records from overseas financial institutions as of 31 December
• Real estate location, acquisition records and documents supporting valuation
• Securities details, quantities and year-end prices
• Passport entry and exit records or other documents confirming your period of stay
• Records of calculations converting foreign currency into yen

Keep these documents after filing in case you are asked to explain them.

Common mistakes

• Testing against the highest balance held during the year. The test is based on 31 December.
• Assuming you are a non-permanent resident simply because you do not hold Japanese nationality. Your total period of stay is also a condition.
• Treating the Overseas Assets Report and the Statement of Property and Liabilities as the same thing. They are separate systems.
• Relying on the previous year’s position. Residency is also determined by your circumstances on 31 December of that year.

How to check the latest information

Search for “Overseas Assets Report” on the NTA website and review the Tax Answers and the Q&A. Deadlines are published for each tax year. Changes to forms and filing methods are also published on the same site. If in doubt, check with your local tax office or a certified tax accountant.

What TIMOA can do

Filing the Overseas Assets Report and determining tax liability fall within the scope of certified tax accountants. TIMOA works with partner tax accountants to support residency classification, identification of overseas assets and filing preparation. We can also review these matters together with inheritance planning and asset management company structuring.

For an overview of our services for high-net-worth clients, see our private client services page.