When a Parent Living in Singapore Dies Leaving Assets in Japan

There are cases where a person who lived in Singapore dies leaving assets in Japan because they once lived in Japan or owned investment real estate there. The heirs are also in Singapore. Only the assets are in Japan.

With this combination, the applicable law may differ depending on the type of asset in Japan. If you prepare an agreement on the premise that “because the asset is in Japan, it can simply be divided under Japan’s Civil Code,” the matter may be stopped at the Legal Affairs Bureau or financial institution.

Key Points of This Article

• Singapore law distinguishes as follows: movables are governed by the law of the decedent’s domicile at death, while immovables are governed by the law of the place where they are located.
• If the decedent’s domicile was Singapore, Japanese real estate may be governed by Japanese law, while deposits in Japan may be governed by Singapore law.
• Common-law jurisdictions use a structure of estate liquidation and distribution, so Japan’s framework for an inheritance division agreement does not apply as-is. The documents required differ by recipient.
• If the decedent was Muslim, inheritance rules under Muslim law are involved.
• To identify assets in Japan, the Real Estate Ownership Record Certificate System, which began operation on February 2, 2026, can be used.

1. The Conclusion May Differ by Type of Asset

Under Article 36 of Japan’s Act on General Rules for Application of Laws, the decedent’s national law must be considered. If the decedent was a Singaporean national, Singapore law is examined.

Singapore law divides inherited assets into movables and immovables.

This can produce a result different from Japan’s method of handling the whole inheritance under one law.

Common-law jurisdictions, including Singapore, use a structure in which the estate is first vested in a personal representative, debts are settled, and the estate is then distributed to beneficiaries. This is not the same mechanism as Japan’s inheritance division agreement, in which all heirs jointly own the estate and divide it by agreement of everyone.

What must be submitted to a Japanese financial institution or Legal Affairs Bureau is handled differently depending on the recipient. The recipient may require a Singapore grant concerning succession, or the matter may be handled with documents used in Japanese practice. Confirmation with the recipient is a prerequisite.

Determining domicile

Under Singapore law, the governing law for movables is determined by the decedent’s domicile at death. Domicile is not simply the place where a person lived; it is a concept judged together with the intention to settle there.

Even after living in Singapore for many years, a person may be judged to have retained the center of their life in Japan. This determination affects which country’s law applies to deposits in Japan.

2. Where the Person Was Muslim

Singapore has a system under which a separate legal system applies to Muslims. If the decedent was Muslim, the inheritance rules differ, making this a point that must be confirmed.

3. Regarding the Parts Governed by Singapore Law

The Japanese Legal Affairs Bureau or financial institution must be shown what range of heirs and shares arise under Singapore law, and what the basis is. In practice, the statutory provisions and their Japanese translations are submitted.

Where an inheritance involving Japanese nationals can be handled by submitting family-register records, the parts governed by Singapore law require the additional work of “proving the content of that country’s law.”

4. Identifying the Heirs

Singapore has no system equivalent to the family register. The following materials are combined to prove the inheritance relationship.

• Birth and death registration records issued by the Immigration & Checkpoints Authority (ICA)
• Marriage certificates issued by the Registry of Marriages (ROM)
• Identity documents such as the NRIC
• A Statutory Declaration prepared before a notary public

The contents required in a Statutory Declaration differ by recipient. Our office prepares a draft after confirming the particulars required by the Japanese financial institution or Legal Affairs Bureau.

If the decedent previously lived in Japan, records may also remain on the Japanese side. A removed residence certificate and the original foreign resident registration record kept by the Immigration Services Agency can serve as materials.

Because the decedent was a foreign national and had no Japanese family register, the statutory inheritance information chart cannot be used.

5. Identifying Assets in Japan

When the decedent lived in Singapore, the heirs may not know the full extent of the assets in Japan. They may be unable to check mail or know which bank held an account.

Under the Real Estate Ownership Record Certificate System, which began operation on February 2, 2026, a request can be made to the Legal Affairs Bureau in one inquiry to identify where in Japan the decedent owned real estate and obtain a certificate. The owner of the real estate or an heir may request it, at any Legal Affairs Bureau nationwide, in person, by mail, or online.

Unregistered buildings, or real estate whose registered address or name does not match the current information, may not be recorded.

6. This Is Separate from Singapore’s Estate Procedures

In Singapore, succession to an estate involves obtaining a Grant of Probate from the court when there is a will, or Letters of Administration when there is no will. This grant has no direct effect on assets in Japan.

When assets exist in both Japan and Singapore, the two procedures must be pursued in parallel.

7. Japanese Inheritance Tax

Assets located in Japan are subject to Japanese inheritance tax even when both the decedent and heirs live in Singapore. The basic deduction is 30 million yen + 6 million yen × the number of statutory heirs, and the filing deadline is 10 months from the day after the day the death was learned of.

Singapore’s estate duty was abolished in 2008. A tax accountant must confirm the scope of taxation on the Japanese side.

8. After Inheriting Real Estate

When real estate in Japan is inherited, even after inheritance registration (mandatory within 3 years from the day the acquisition is learned of) is completed, property tax payments, building management, and dealings with neighbors continue.

In addition, registration of changes to an address or other information has been mandatory since April 1, 2026. When an owner changes an address, name, or similar information, registration must be made within 2 years from the date of the change; failure to do so without a legitimate reason may be subject to a non-penal fine of up to 50,000 yen. Even where the address or other information was changed before April 1, 2026, the change must be registered by March 31, 2028.

9. Estimated Timeline

The overall guideline is 8 months to 1 year.

If the recipient requires a Singapore grant concerning succession, the time needed to obtain it is added.

Our Office’s Services

Gyoseishoshi Arch Office has been handling procedures for people with international ties for more than 15 years, based in Osaka. We can assist in Japanese, Chinese, and English.

• Organizing the division of governing laws (which assets may be governed by Japanese law or Singapore law)
• Identifying real estate using the Real Estate Ownership Record Certificate System and making inquiries to financial institutions
• Preparing a Statutory Declaration draft tailored to the recipient’s requirements
• Preparing an inheritance division agreement
• Preparing the complete set of supporting documents for each financial institution and assisting with cancellation and refund procedures
• Coordinating with a judicial scrivener when inheritance registration is required and with a tax accountant when an inheritance tax return is required

Frequently Asked Questions

Q. Can deposits in Japan also be divided under Japan’s Civil Code? A. If the decedent’s domicile was Singapore, deposits and other movables may be judged under Singapore law. Confirmation is needed before preparing an agreement.

Q. How is it determined whether the domicile was Singapore or Japan? A. The determination considers not only the period of residence but also the actual circumstances of life, ties to Japan, residence-registration records, and other factors as a whole.

Q. We do not know where the decedent owned real estate. A. The Legal Affairs Bureau can be queried in one request through the Real Estate Ownership Record Certificate System. An heir may also request it.

Q. Can the procedures be completed without coming to Japan? A. This is often possible for inheritance of deposits. If the real estate will also be sold, it may be necessary to appoint a representative or come to Japan.

Q. All the heirs are in Singapore. Who communicates with the Japanese contact point? A. It is usual to appoint a professional in Japan. The power of attorney also requires authentication by a notary public.

Contact Us

For a consultation, please prepare the decedent’s nationality, date of death, last place of residence and history of residence in Japan, religion, the number, relationship, and nationalities of the heirs, and the types of assets in Japan. We can respond in Japanese or Chinese.

Related Articles

• When a Singaporean parent living in Japan dies and the heirs are in Singapore
• The process when inheriting real estate in Japan
• Basics of international inheritance when there are assets in Japan
• When inherited real estate in Japan cannot be managed