Switzerland-Japan Cross Border Inheritance Tax Guide
Last updated: 30 Sep 2025
Switzerland × Japan: Inheritance & Gift Tax — No IHT Treaty
Switzerland and Japan do not have a bilateral inheritance/gift tax treaty. Relief from double taxation is therefore handled through domestic rules (Japan: national inheritance/gift tax; Switzerland: cantonal inheritance/gift taxes; no federal IHT). There is an income tax treaty (DTA) between Japan and Switzerland, but it does not govern inheritance/gift tax.
Japan levies national inheritance & gift tax; Switzerland’s regimes are cantonal (no federal IHT). JP–CH have an income tax treaty only.
At a glance
No CH–JP IHT treaty
- Japan and Switzerland have no inheritance/gift tax treaty; only an income-tax DTA. :contentReference[oaicite:0]{index=0}
- Relief is via domestic mechanisms (credits/exemptions) and careful situs classification.
Why this matters
- Japan’s IHT is **national** with progressive rates (up to high brackets) and a formulaic basic exemption. :contentReference[oaicite:1]{index=1}
- Switzerland taxes are **cantonal**; spouses are generally exempt and many cantons exempt children. :contentReference[oaicite:2]{index=2}
Japan: what’s taxed and who pays
| Topic | Rules (high level) | Source |
|---|---|---|
| Scope | Japanese inheritance tax applies when statutory conditions are met; scope depends on decedent/heir status and asset location. | NTA English pages |
| Basic exemption | ¥30,000,000 + ¥6,000,000 × number of statutory heirs. | NTA: “Cases where inheritance tax is imposed”. |
| Gift tax | National gift tax complements IHT with annual exemptions; aggregation/look-back rules apply in certain cases. | MoF/NTA guidance |
See the NTA English overview and “Cases where inheritance tax is imposed” for formulae and scope definitions.
Switzerland: cantonal regimes & exemptions
- No federal inheritance tax; cantons levy inheritance/gift taxes. Spouses are generally exempt; many cantons broadly exempt children. :contentReference[oaicite:3]{index=3}
- Rules and rates vary widely by canton; check local law and procedures. See our Swiss Inheritance Tax by Canton.
Situs drivers (high level)
| Asset | Situs (typical) | Comments |
|---|---|---|
| Immovable property | Where the property is located | Primary taxing right usually at situs. |
| Tangible movables | Physical location at death/transfer | Keep inventory/location proofs. |
| Bank claims / deposits | Debtor location (bank) | Statements and bank domicile evidence are key. |
| Shares / stock | Place of incorporation | Japanese KK → JP situs; Swiss AG/GmbH → CH situs. |
Double-tax relief in practice (no treaty)
- Japan: Uses domestic rules to determine who is taxed and on what; check NTA for filing/payment obligations and any unilateral relief mechanics (Japan does not have an IHT treaty with Switzerland). :contentReference[oaicite:4]{index=4}
- Switzerland: Relief, if any, is determined at cantonal level (and via international practice); given the absence of a CH–JP IHT treaty, careful asset-by-asset situs and documentation are essential. General overviews confirm CH has IHT treaties with certain countries (US, UK, DE, etc.), but not Japan. :contentReference[oaicite:5]{index=5}
Worked example (numbers)
- Decedent: Japanese national, resident in Japan at death.
- Heir: Adult child resident in Zurich (Switzerland).
- Assets:
- JP-situs securities (Japanese shares): ¥200,000,000
- Swiss bank portfolio (Zurich): CHF 800,000 (assume ≈ ¥130,000,000 for illustration)
- Assumptions (illustrative only): 1 statutory heir → basic exemption = ¥30,000,000 + 1×¥6,000,000 = ¥36,000,000; ignore spouse/charity/business reliefs; Zurich typically exempts children from inheritance tax.
Basic exemption: − ¥36,000,000 ⇒ taxable ≈ ¥294,000,000
Apply JP progressive IHT rates (illustrative): compute per NTA tables ⇒ material JP IHT due.
Result: no Swiss inheritance tax due on the Swiss portfolio (but confirm canton and any gift rules).
With no CH–JP IHT treaty, there is usually no Swiss credit to claim. The burden sits on the JP side per national rules.
This is simplified and for education only. Actual results depend on domicile, residence windows/look-backs, allowances, debts, valuations, FX, and filings.
Planning checklist (no legal/tax advice)
- Determine scope: JP residence/domicile tests and CH canton of heir; identify worldwide vs. situs-only outcomes.
- Map assets by situs (JP vs. CH) and type; securities vs. real estate can flip primary taxing rights.
- Model JP liability: apply basic exemption formula and progressive brackets; test gifting vs. bequest.
- Check canton exemptions (spouse/children often exempt) and any cantonal gift tax angles.
- Paper the file: valuations at death, situs evidence, official assessments/payment proofs; anticipate requests from both tax authorities.
FAQ
Is there a Switzerland–Japan inheritance/gift tax treaty?
No. They have an income tax treaty, but not an inheritance/gift tax treaty. :contentReference[oaicite:6]{index=6}
Do Swiss cantons always tax inheritances?
No. Spouses are generally exempt and many cantons broadly exempt children. Always check the relevant canton rules. :contentReference[oaicite:7]{index=7}
What is Japan’s basic exemption for inheritance tax?
¥30,000,000 + ¥6,000,000 × number of statutory heirs. See NTA’s English page. :contentReference[oaicite:8]{index=8}
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