For a non-resident to file returns, pay tax and receive refunds in Japan, appointing a tax agent (nōzei kanrinin) is a practical necessity. A tax agent is a person who handles national tax matters on behalf of a taxpayer who has no domicile or residence in Japan, as provided for in Article 117 of the Act on General Rules for National Taxes. Specifically, the tax agent, on the taxpayer’s behalf:
(i) files tax returns;
(ii) receives documents from the tax office (enquiries, notices and the like);
(iii) pays taxes; and
(iv) receives refunds.
Who can serve — and the zeirishi limits
Either an individual or a corporation may serve as a tax agent. Note, however, that tax representation — preparing tax returns and giving tax advice — is work reserved by law to certified public tax accountants (zeirishi); a tax agent who is not a tax accountant can act only as an administrative point of contact. If a certified public tax accountant is appointed as tax agent, everything from receiving documents to preparing returns and dealing with the tax office can be handled together.
The specified tax agent system
The 2021 tax reform introduced the specified tax agent system, effective January 1, 2022. Where a taxpayer who should appoint a tax agent fails to appoint one and file the notification, the tax authorities may first request that the taxpayer submit the notification of a tax agent; if the taxpayer does not respond, the authorities may designate a related party in Japan — such as a lessee or a business counterparty — as the taxpayer’s specified tax agent.
Under this system, even if a taxpayer leaves the position unfilled, a tax agent will ultimately be put in place by designation of the tax authorities. That being so, it is more sensible to appoint a tax agent you trust, in advance and of your own choosing. Doing so has three practical advantages: (1) reliable management of filing and payment deadlines; (2) secure receipt of refunds; and (3) a single point of contact for dealings with the tax office.
When you need a tax agent
Typical situations in which a tax agent is needed are as follows:
- The annual income tax return where you lease out real estate located in Japan;
- The capital gains return where you sell the real estate (including the settlement of tax withheld at source);
- Departure from Japan (returns and payments that fall due after you leave); and
- Inheritance tax filing and payment where you inherit assets in Japan while living abroad.
How to appoint a tax agent
For national taxes, the appointment is made by filing a Notification of Tax Agent with the tax office that has jurisdiction over you; a separate form is used for inheritance and gift tax. The notification does not reach local taxes. If you own real estate in Japan, the real estate acquisition tax is a prefectural tax, and the fixed asset tax and city planning tax are municipal taxes; each has its own appointment, made by filing a tax agent declaration (nōzei kanrinin shinkokusho) with the prefecture and the municipality where the property stands; in Hokkaido and in Sapporo, it is due within ten days of the day the need arises. Where the agent lives outside the prefecture’s or the municipality’s area, the filing is an application for approval rather than a declaration. For a property in Sapporo, that means three filings: the tax office, Hokkaido’s prefectural tax office and the City of Sapporo.
Without the prefectural and municipal filings, the acquisition tax notice and each year’s fixed asset tax notice are posted to your address abroad. A notice that arrives late, or not at all, does not extend the payment deadline, so late-payment charges accrue, and after a demand the tax can be collected from your assets in Japan, the property included. For an owner, the appointment is therefore best made in all three places on the day of completion.
And while anyone with an address in Japan can be named, appointing a zeirishi as your tax agent means the receipt of documents, the preparation of returns, payments and refunds are all handled through a single point of contact — with the deadlines managed as part of the engagement.
Whether the occasion is leasing or selling real estate, leaving Japan, or an inheritance, the tax agent is the entry point to the procedures and the first matter to consider.
We provide this as a standing service — acting as tax agent and handling the related filings for non-residents. Details: our tax agent (nōzei kanrinin) service.
If you are planning to leave Japan, please include your planned departure date when you write — it is the first thing we need to know.
Need a tax agent in Japan?
We act as tax agent (nōzei kanrinin) and handle the related filings for non-residents — by email.
Every enquiry is read and answered personally by the principal — first reply within 3 business days.
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