Frequently Asked Questions
Overseas Asset Reporting and CRS — What to File, By When, and What Happens If You Don’t
This is the question we field most often from people holding assets abroad. The Overseas Assets Report is a disclosure obligation, not a payment one — but whether you filed it directly changes how heavy the penalty surcharge is later. CRS is a separate regime, and it is not something you file yourself.
Who has to file an Overseas Assets Report?
A resident (excluding a non-permanent resident) whose overseas assets total more than ¥50 million as of 31 December must file by 30 June of the following year.
- The test date is 31 December. It is the total on that date, not movements during the year.
- It is filed with the district director of the tax office for the place of income tax payment (or the address, or place of residence where there is no address in Japan).
- A “Summary Table of Overseas Assets” must be prepared and attached.
A “resident” is an individual having an address in Japan, or who has had a place of residence in Japan continuously for one year or more. A “non-permanent resident” is a resident who does not hold Japanese nationality and whose total periods of having an address or place of residence in Japan within the past 10 years amount to five years or less.
Source: 国税庁 タックスアンサー No.7456
What are the penalties for not filing, or for filing false information?
Filing a report containing false statements, or failing without justifiable grounds to file by the deadline, may be punished by confinement (kōkinkei) for up to one year or a fine of up to ¥500,000.
Where the failure to file by the deadline lacked justifiable grounds, the sentence may be remitted depending on the circumstances. Note the penalty is now stated as “confinement” (kōkinkei) rather than the older “imprisonment with labour” — many older commentaries still carry the pre-reform wording.
Source: 国税庁 タックスアンサー No.7456
What difference does filing actually make?
Whether you filed determines whether a later underpayment attracts a 5 percent reduction or a 5 percent increase in the penalty surcharge.
| Situation | Effect on the penalty surcharge |
|---|---|
| Filed on time, and the asset is listed | Reduced by 5 percent |
| Not filed on time, or the asset is not listed (including where material items are inadequately stated) | Increased by 5 percent |
| Failed to produce requested supporting documents by the specified deadline before an amended return | No reduction; the increase becomes 10 percent |
The deadline for producing documents is set within 60 days of the request, taking account of the time normally needed to prepare. In other words, filing the report but being unable to produce the underlying documents removes the reduction.
Source: 国税庁 タックスアンサー No.7456
In the year an inheritance occurs, must the inherited overseas assets be listed?
For the year in which the inheritance begins, the report may be filed without listing the overseas assets acquired by that inheritance or bequest.
In that case the ¥50 million threshold is also tested excluding the value of those inherited overseas assets. Where the holder is not at fault for a failure to file or list such assets, the increase in the penalty surcharge does not apply to them.
Source: 国税庁 タックスアンサー No.7456
Given CRS, don’t the authorities already know — why file at all?
CRS is a regime under which financial institutions report to the authorities and the authorities exchange information between themselves. It does not replace your own filing obligation; they are separate regimes.
Financial institutions in Japan report specified non-residents’ financial account information to the district director by 30 April each year, and that information is automatically exchanged with foreign tax authorities under the exchange-of-information provisions of tax treaties. Those opening accounts on or after 1 January 2017 must submit a notification stating their country of residence.
Recent change: the 2024 tax reform revised the reporting regime. The revised regime takes effect from 2026, with reporting and exchange conducted under it from 2027 onwards. The scope of reportable items has been expanded, so anyone working from an older understanding should check their position now.
Source: 国税庁 CRSコーナー
What this page does not cover
It does not cover how to complete the report, how to value assets, how penalty surcharges are calculated, or whether an amended return is needed. Those fall under Article 2 of the Certified Tax Accountant Act and are handled by our partner licensed tax accountants. What we work on is the holding structure: which assets held through which entity, and how that changes both the reporting obligation and the taxable perimeter.
Primary sources
Related services and questions
- China–Japan Cross-Border Wealth Structure
- Financial Architecture Diagnostics
- Japan’s exit tax — where the ¥100 million line falls
- The inheritance tax “10-year rule”
Get in touch
Changing the holding entity changes both the reporting obligation and the taxable perimeter — but many of these points cannot be fixed after the fact. ceo@seisei.tokyo
SEISEI provides financial and management consulting. It does not constitute tax representation, preparation of tax documents, or tax consultation as defined in Article 2 of Japan’s Certified Tax Accountant Act. Filings and tax computations are handled by partner licensed tax accountants (zeirishi).