France–Japan — Tax Treaty

1One convention, signed at Paris in 1995 — and the credit ceiling the courts apply to the letter

One instrument does all the treaty work of this relationship. Signed at Paris on 3 March 1995 in replacement of the 1964 text, the convention entered into force on 24 March 1996 and has applied since 1 January 1997; the avenant and exchange of letters of 11 January 2007, in force from 1 December 2007, brought it to the modern standard and inserted a detailed entitlement article reserving certain benefits to qualified persons, individuals qualifying as of right (article 22A). The multilateral instrument (the anti-abuse rule agreed internationally in 2017) followed: both states signed on 7 June 2017, both lodged their notifications on 26 September 2018, and it took effect for both on the same day, 1 January 2019 — a rare synchrony — introducing the principal-purpose test, by which an advantage may be refused where securing it was a principal object of an arrangement, and rewriting the property-rich clause examined in § 4. Article 2 lists the taxes covered, and the list repays attention: on the French side the income tax, the corporation tax and, by name, the CSG and the CRDS; on the Japanese side the income tax, the corporation tax and the local inhabitant taxes. Nothing on fortune appears on either side, and the administration's treaty list of 29 April 2026 shows no succession or gift instrument with Japan — the absence around which § 6 of this brief is built. Quotations follow the French text published at the Journal officiel, in the administration's consolidated presentation.

Who counts as a resident — and what Japan does on its own side

Where both states claim a person, article 4 §2 assigns them down the OECD cascade — permanent home, centre of vital interests, habitual abode, nationality, mutual agreement — while French domestic law asks its own version of the question through CGI article 4 B, on the family's foyer, the principal place of stay and the centres of professional and economic interest. The convention exists to settle the conflicts those two enquiries generate. Japan's own system runs on different lines: inheritance and gift taxation there falls on the recipient rather than the estate, graded by the heir's or donee's residence and nationality at progressive rates that reach 55%, with rules for foreign nationals turning in part on ten years of presence within the preceding fifteen; no net-wealth tax exists. Those propositions are stated at orientation level only — the verified ground of this brief is French law and the 1995 convention, and the Japanese reading belongs with the family's advisers in Tokyo.

The credit ceiling, three times before the Conseil d'État

Where the 1995 convention has been litigated at the supreme level, the subject has always been article 23's credit machinery — and once the court construed the Japanese text itself. A French banking establishment had borrowed securities of companies in nine states, Japan among them, collecting their dividends net of each state's withholding while contractually bound to pay the amounts straight on to the lenders; it claimed the treaty credits against its French tax. The court found the answer written into the convention: paragraph 11 of its protocol defines the French tax against which the Japanese credit is measured as the tax computed on the NET income, after the charges directly linked to earning it — and with the dividends passed on in full, nothing net remained, so the credit came to zero (CE, 11 May 2021, n° 403692). Two years later a banking group in a deficit year asked to carry unused credits forward to a profitable exercise; the court refused — read according to the ordinary meaning of their terms, the elimination articles promise a credit against the year's French tax and nothing further (CE, 8 March 2023, n° 456349). The reading runs in both directions: where the administration's published commentary cut a treaty credit back further than the texts allow, the court held the commentary unlawful, the 1995 convention among those invoked (CE, 15 November 2021, n° 454105). By contrast, no reported decision of the supreme court tests this convention's residence article or its property articles on Japanese facts — and at death there is no France–Japan case law at all, for the structural reason that no treaty exists there to construe. The accumulation described in § 6 has never seen a courtroom and cannot: each state simply applies its own statute.

Sources considered: 1995 convention (CML consolidation) arts. 2, 4, 22A, 23 §1, protocol §11; BOI-ANNX-000306 (29 April 2026); CE n° 403692, n° 456349, n° 454105; CJUE Société Générale C-403/19 — decision texts read. Scope note: the credit decisions arise on corporate dividend facts; none rules on property income, gains or an estate.

Reviewed as at 10 August 2026 · 1995 convention (CML consolidation) arts. 2, 4, 22A, 23, protocol §11; BOI-ANNX-000306 (29 April 2026); CE n° 403692, n° 456349, n° 454105 — decision texts read

2What you pay to buy a property in France, and what it costs you every year

The purchase runs on the sequence French practice fixes: an offer; the pre-sales contract (compromis de vente), with its ten-day cooling-off period and a deposit of customarily 10%; conditions precedent; then the authentic deed before the notaire — the public officer who draws up and registers the deed — who collects the duties and registers the title. The notaire holds a public office and is not the buyer's advocate: a family managing the file from Tokyo, eight hours ahead of the coast, will usually add advisers of its own and grant a power of attorney for the deed. One point belongs at the top of the calendar rather than the end: since no treaty governs what becomes of the property at death or by gift, the structure questions of § 3 and § 6 should be answered before the pre-sales contract is signed — the acquiring vehicle resists change once the sequence is under way. On the collection's common yardstick — the €4.9M median villa of Cannes and its hills in the DVF register — the buyer pays transfer duties and land-registration taxes of about 5.81% (€284,526), notaire's émoluments and disbursements of roughly €61,250 on the regulated sliding scale, together an indicative 7% all-in (≈ €345,776) on an existing property. A new-build VAT regime, furniture carve-outs or mortgage security will alter the arithmetic; the notaire itemises the actual deed.

The wealth tax arrives without a Japanese counterpart

Above €1,300,000 of taxable French real-estate assets, CGI article 964 institutes the annual wealth tax; for a person not domiciled in France the base takes in property located in France and the fraction of any company's shares that stands for such property (article 965, 2°). The treaty position here is neither favourable nor unfavourable — it is missing. The 1995 convention covers income alone, so no article says who may charge it, softens it or promises a credit; the Denmark and Brazil relationships sit on the same footing, while the German text of 1959, which covers fortune expressly, marks the contrast. Japan levies no net-wealth tax, so the IFI arrives without a counterpart rather than as one half of a double charge — an annual French cost resting on domestic law alone, attached to the property whatever the owner's treaty residence. The value declared each year is the owner's own detailed estimate of real market value (CGI article 973 I). The local charges then follow the deed: the annual local property tax (taxe foncière) is voted commune by commune; a furnished second home in a designated high-demand area (zone tendue) — the marquee Riviera communes qualify — may in addition carry the surcharge (surtaxe) on the taxe d'habitation for secondary residences, and every owner files the annual occupancy declaration. Communal rates move year to year, so this brief re-verifies them at each edition instead of printing a table that would age.

Our agency prepares a free valuation for owners at valuation.elenaagueeva.com. An agent contacts you within 48 hours to arrange a visit.

It rests on the same official records a French property valuer (expert immobilier) works from: the government's register of recorded sale prices, the cadastre, and the planning permits granted on the parcel. The agent then visits to appraise the view, the garden, and the quality of the construction and the finishes. The valuation report (avis de valeur) is produced within 48 hours of the visit.

The same figure carries your French filings. Wealth tax, the 3% company tax and gift duty are all declared at the property's market value. The law takes that value from your own detailed estimate (articles 761 and 973 of the tax code), and asks no particular valuer to produce it. A court-appointed expert (expert judiciaire) belongs to litigation, not to a declaration. If the administration challenges your figure, a dated, written valuation resting on comparable sales is what supports it.

The first valuation of a property is free for its owner or seller. A repeat valuation of the same property, or one commissioned by a family office, a bank or another adviser for a client, is a billable engagement — ask us for terms.

Sources considered: 1995 convention art. 2; CGI arts. 964, 965 2°, 973 I; cost scales stated for orientation, itemised when our agency takes the file. Scope note: no Japanese wealth charge exists — the IFI is the property's principal recurring cost above the threshold.

Reviewed as at 10 August 2026 · CGI arts. 964–965, 973 I; 1995 convention art. 2

3Five ways to own a French property, and what follows from each

Holding structures appear here, per this collection's doctrine, as questions for analysis rather than recommendations. For a Japanese buyer one fact organises the whole analysis: with no succession or gift convention, whatever the deed creates will be read twice — once by France, once by Japan — each under its own law, and nothing arbitrates between the two readings.

Direct ownership

Simplicity, and France taxes it at every stage. On a sale France taxes as the state where the property stands and Japan credits the French charge (articles 13 §1 and 23 §2 a); at death French duty attaches to the property while Japanese inheritance tax follows the resident heir — the two-sided assessment § 6 develops.

A Japanese or other foreign company

Confidentiality and consolidation, at three French prices. The annual 3% tax on entities holding French property (CGI articles 990 D and 990 E) asks its disclosure question every year; the property fraction of the shares bears the IFI regardless; and at death French law reads through companies the family holds above one half, taxing the property as if held in the deceased's own name (CGI article 750 ter, 2°).

A French SCI

An SCI (a French property-holding company) offers governance, co-ownership between family members and access to French financing. How Japanese law classifies the SCI is a question for Tokyo counsel; on the French side the property fraction bears the IFI, a sale of the shares stays French under the 365-day property-rich clause (article 13 §3), and at death article 750 ter taxes the property as if the family held it directly.

A trust in the chain

Trust arrangements are familiar ground in Japanese practice, and French law meets them with machinery of its own: trustee reporting under CGI article 1649 AB, the dedicated levy of article 990 J where declaration fails, and transmission rates that reach 60% where beneficiaries' shares are undetermined (article 792-0 bis). Either route calls for counsel on both sides before the pre-sales contract.

Giving your children the ownership now, and keeping the use for life (démembrement)

Alongside the loan, the proposal most often heard divides the property itself: the buyer keeps the usufruct — the property's use and income for life — and gives the bare ownership to the children now. French law prices that split on an age scale: by CGI article 669 the bare ownership stands at 60% of full value while the usufructuary is aged 61 to 70, and at 70% from 71 to 80; gift duty falls on that fraction at today's value, and when death later reunites full ownership no second French transmission is taxed, provided the conditions of article 751 were kept — a notarised gift, more than three months before death, valued on the article 669 scale. The wealth tax does not move: article 968 keeps the entire value in the usufructuary's IFI base. For a Japanese family the treaty landscape is barer than in most relationships — the gift falls under no convention, France taxes the French property on its own scale, and whatever Japan asks of the donee follows Japanese law alone, with such relief as that law itself provides.

Borrowing against the French property cuts French wealth tax — within the code's three limits

The financing conversation runs as it does elsewhere on this coast: a loan from the buyer's bank, secured on a pledged portfolio, so that liquidity remains invested while the debt reduces the taxable base — and with no Japanese wealth charge for a loan to work against, the deduction is measured entirely on the French base. Acquisition debt owed to a bank is deductible from the IFI base under CGI article 974, while financial assets sit outside that base altogether. The boundaries are three. Loans repaying capital at term are treated as if they were being repaid gradually, the deduction declining pro rata over the loan's life, and by one twentieth a year where no term is fixed. Where taxable property exceeds €5M and debts exceed 60% of its value, the excess is deductible only as to half, unless the borrower shows the loan was not contracted mainly for tax. And the debt must be real — actually drawn, actually serviced, at market terms; routed through a shareholder account of an SCI it ceases to count for valuing the shares (article 973). Leverage moderates the IFI in its early years and fades by design — a calendar best examined before the pre-sales contract rather than after.

Sources considered: CGI arts. 669, 750 ter 2°, 751, 792-0 bis, 968, 973–974, 990 D–990 E, 990 J, 1649 AB; 1995 convention arts. 13 §3, 23 §2 a. Scope note: structures are questions, not recommendations, settled with counsel in France and in Japan.

Reviewed as at 10 August 2026 · CGI arts. 669, 750 ter, 751, 792-0 bis, 968, 973–974, 990 D–J, 1649 AB; 1995 convention arts. 13 §3, 23 §2

4What you pay when you sell

France taxes first, as the state where the property stands: article 13 §1 assigns gains on French immovables to France, and paragraph 3 of the same article — rewritten by the multilateral instrument — reaches gains on shares and comparable interests, partnership and trust interests included, that drew more than half their value from French real estate at any time in the 365 days before the sale. For a Japan-resident seller the French charge runs under CGI article 244 bis A: the taxable gain is reduced by an ownership-duration allowance of 6% for each year of ownership beyond the fifth and 4% for the twenty-second (article 150 VC), the income-tax component then applying at 19% (article 200 B) and extinguishing after 22 years, while the social levies extinguish after 30. Taxable gains above €50,000 bear in addition the progressive surcharge of article 1609 nonies G, which reaches 6% at the levels this market transacts. Per €1,000,000 of gross gain on a property sold at the Cannes median of €4.9M: after 10 full years the allowance is 30%, leaving €700,000 taxable, €133,000 of income tax and a €42,000 surcharge; after 15 years, 60%, €400,000, €76,000 and €24,000; after 22 years the income-tax component is extinct.

Two administrative features mark the file of a seller resident in Japan. The social levies come at the full combined 17.2%: the reduced solidarity rate belongs to sellers within the European social-security coordination, an affiliation Japanese residence does not carry, whatever bilateral arrangements exist between the two states' pension systems. Notably, the 1995 convention names the CSG and the CRDS among the French taxes it covers, so both enter the treaty's credit machinery as French tax; how far the Japanese credit absorbs them is a question of Japanese law, taken up when our agency takes the file. And representation: domiciled outside the EU and the EEA, the seller appoints a representative accredited by the French administration, who answers for the filing and the payment (article 244 bis A, IV), the administration's instruction of 22 January 2025 granting automatic exemptions for sales at €150,000 or less per seller and for sales wholly exempt through the thirty-year clock; the deed's notaire ordinarily arranges the appointment.

Japan then answers as the residence state. France taxing the gain first does not stop Japan taxing it too: Japan taxes the gain under its own law and credits the French charge within the limit of the Japanese tax on that income (article 23 §2 a) — and the case law of § 1 is the reminder that such ceilings are applied to the letter. Selling the property or selling the shares of a property-rich company changes the pool of buyers and the French filing mechanics more than it changes who taxes the gain, which article 13 keeps French on both routes; the choice belongs before marketing begins.

The one Japan-resident seller the Conseil d'État has ruled on — CE n° 385737

The reported jurisprudence of this relationship holds exactly one property seller, and his case repays reading. A resident of Japan sold his undivided rights in a Paris immovable in 2007, a year in which the non-resident levy still ran at one third for sellers established outside the European Economic Area while residents bore 16%; he paid at the third, then reclaimed the difference down to the resident rate. The lower courts granted the restitution, and the Conseil d'État rejected the minister's final appeal — settling, in the process, that the ordinary two-year reclamation window applies to the 244 bis A levy even though a representative pays it on the seller's behalf (CE, 15 April 2016, n° 385737). Two observations carry forward: the ground of that dispute has since been closed by statute — the income-tax component now runs at the same 19% whatever the seller's residence — and the convention itself was never in the argument: France's entitlement to tax the gain, which article 13 settles, went unquestioned from first instance to cassation. What a Japan-resident seller litigates in France, on this record, is rate mechanics and procedure, not France's right to tax at all.

Leaving after the sale — what the exit tax does and does not reach

France's exit tax (CGI article 167 bis) concerns securities, not property: it reaches persons who were French-domiciled for at least six of the ten years before leaving, and taxes the unrealised gains on securities holdings above €800,000 in value, or stakes of 50% or more of a company's profits, as they stand on the day of departure. A property already sold has settled its own tax under the regimes above, and the sale proceeds are not within the charge. Shares of a family SCI follow the property rather than the portfolio: so long as the company keeps the ordinary income-tax regime, gains on its property-rich shares remain within the real-estate regime (CGI article 150 UB) and outside the exit tax. A family that leaves before six years of French domicile stands outside the latent-gains charge altogether. Where the machinery does apply, payment is generally deferred, and the assessment lapses where the securities are still held two years after departure — five where the portfolio exceeded €2.57M — or upon a return to France.

Sources considered: 1995 convention arts. 13 §§1, 3, 23 §2; CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 244 bis A (incl. IV), 1609 nonies G; LPF art. R* 196-1; BOI-RFPI-PVINR-30-20 (22 January 2025); CE n° 385737 — decision text read. Scope note: n° 385737 rules on the reclamation deadline under a rate schedule since repealed; it does not construe the 1995 convention.

Reviewed as at 10 August 2026 · 1995 convention arts. 13, 23; CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 244 bis A, 1609 nonies G; LPF R* 196-1; CE n° 385737

5Renting before you buy, and renting your property out

A first year in a rented property remains the sensible rehearsal, and one caution belongs in plain words. CGI article 4 B fixes French tax domicile by the foyer, the principal place of stay and the centres of professional and economic interest, and a lease displaces none of the three: the rented property that becomes the family's effective home can found French residence, worldwide consequences included, long before any deed is signed — at which point the cascade of article 4 §2 of the convention decides which state gives way. Whether the trial takes the form of furnished seasonal rentals or the one-to-three-year civil lease is chiefly a question of exit flexibility, matched to what the trial is actually for.

Renting the property out reverses the flow. Non-residents' French-source rental income — furnished rentals at this price point included — falls under the minimum-rate regime of CGI article 197 A, at 20% at least up to the second-bracket ceiling and 30% beyond, unless a lower worldwide effective rate is demonstrated; the social levies add their full 17.2%, Japanese affiliation lying outside the European coordination. The convention assigns the income to the state where the property stands, whatever the form of exploitation (article 6 §§1 and 3) — and France taxing it does not stop Japan taxing it: Japan taxes its resident on the same income and credits the French tax (article 23 §2 a) — the CSG and CRDS among the creditable amounts, both being taxes the convention names, on mechanics that belong with the family's advisers in Tokyo.

Sources considered: CGI arts. 4 B, 197 A; 1995 convention arts. 4 §2, 6 §§1 and 3, 23 §2 a. Scope note: treatment turns on the form of exploitation and on affiliation, both questions of fact.

Reviewed as at 10 August 2026 · CGI arts. 4 B, 197 A; 1995 convention arts. 4 §2, 6, 23 §2

6What happens to the property when you die, or give it away — and why both states tax it with nothing between them

This is the section the absence of a treaty writes, and on this pair it writes the hardest page in the collection: the two systems add, and no instrument stands between them. French duty attaches to the property because it stands in France, whatever the owner's domicile, for estates and for lifetime gifts alike, and reads through interposed companies — an immovable held through entities in which the deceased or donor, together with spouse, ascendants, descendants or siblings, holds more than half the interests is taxed as if it were held directly (CGI article 750 ter, 2°). Where the deceased was French-domiciled, or an heir has been French-resident for six of the ten preceding years, France taxes the worldwide transmission instead (750 ter, 1° and 3°). The scale is article 777's: progressive to 45% in the direct line beyond €1.8M per share, after the €100,000 per-child allowance of article 779, the surviving spouse exempt in succession. Japan, for its part, taxes the Japan-resident heir or donee on what is received — worldwide where the heir is within the full reach of Japanese law, at rates reaching 55%, stated here at orientation. Nothing coordinates the two assessments. France's credit mechanism, article 784 A, operates only in the worldwide cases of 750 ter 1° and 3°, and even there credits foreign duty solely against the tax on assets outside France — by its terms it never relieves the French property itself. Japan's unilateral foreign-tax credit may absorb part of the French charge on the Japanese side, a question of Japanese law examined with Tokyo counsel. The values declared for the duty are the owner's own detailed estimate of market value (CGI articles 761 and 1897).

A Japanese-law election is open — and French forced heirship meets it on settled terms

The one instrument that does speak is European: under Regulation 650/2012, which France applies to all successions, a Japanese national habitually resident in France may elect Japanese law for the succession as a whole. The election meets French forced heirship on settled terms. Japanese law protects children through a reserve of its own — the iryūbun, a monetary claim against the estate rather than a share in kind, stated here at orientation — and the compensatory levy French law added in 2021 arises only where the foreign law applicable to the succession permits no protective reserve mechanism at all (Code civil, article 913, al. 3), alongside its condition that the deceased or a child be an EU national or resident. A reserve-type system on the Japanese model is therefore unlikely to trigger it, though the point is assessed on the succession's actual facts. The choice of law, the matrimonial regime carried into the purchase, and the calendar of any gifts are questions for counsel on both sides, best answered before the pre-sales contract.

Sources considered: CGI arts. 750 ter, 761, 777, 779, 784 A, 1897; Code civil arts. 912–913; EU Reg. 650/2012. Scope note: Japanese inheritance and gift law is stated at orientation; the iryūbun reading has not been tested against article 913 al. 3 in any reported decision.

Reviewed as at 10 August 2026 · CGI arts. 750 ter, 761, 777, 779, 784 A, 1897; Code civil art. 913 al. 3; EU Reg. 650/2012

7The eight questions Japanese owners ask most

Does a Japan resident pay French wealth tax on a Riviera property?

Yes — the IFI applies once French real-estate assets pass €1.3M, held directly or through the property fraction of company shares (CGI article 964). Because the 1995 convention covers income alone, no treaty article limits or softens the charge; Japan levies no net-wealth tax of its own, so the cost arrives without a counterpart, resting entirely on French domestic law.

Which country taxes the succession on a French property?

Both, with nothing to coordinate them. France taxes the property because it stands in France, reading through family-held companies (CGI article 750 ter), at up to 45% in the direct line; Japan taxes its resident heirs on their worldwide receipts at up to 55%. The French credit of article 784 A concerns only foreign duty on assets outside France and never lightens the property's own charge; what relief exists comes from Japan's unilateral foreign-tax credit, under Japanese law.

Are lifetime gifts covered by the France–Japan treaty?

No. The 1995 convention governs income taxes only, and the French treaty list records no succession or gift instrument with Japan. A gift of the property or of its bare ownership bears French gift duty because the property is in France, while any Japanese charge on the donee follows Japanese law separately, with such relief as that law provides.

Who taxes the gain when a Japan resident sells a French property?

France first, where the property stands (article 13 §1), under CGI article 244 bis A with the duration allowances — the income-tax component lapsing after 22 years, the social levies after 30. Japan then taxes the same gain and credits the French charge within the limit of its own tax (article 23 §2 a). Property-rich shares follow the same route under the 365-day clause the multilateral instrument added (article 13 §3).

Does the sale require a fiscal representative?

In principle, yes: a seller domiciled outside the EU and the EEA appoints a representative accredited by the French administration, who answers for the filing and the payment (CGI article 244 bis A, IV). Automatic exemptions apply to sales at €150,000 or less per seller and to sales wholly exempt through the thirty-year holding clock; the deed's notaire ordinarily arranges the appointment where one is needed.

Is rental income from France taxed if the owner lives in Japan?

Yes. France taxes it first as the state where the property stands (convention, article 6), under the minimum-rate regime of CGI article 197 A — 20% at least, then 30% beyond the second-bracket ceiling — with 17.2% social levies in addition. Japan taxes the same income in its resident's hands and credits the French tax under article 23 §2 a of the convention.

Does French forced heirship bind a Japanese family?

Less than is often assumed. Under EU Regulation 650/2012 a Japanese national habitually resident in France may elect Japanese law for the whole succession, and Japanese law carries a reserve of its own — the iryūbun, a monetary claim against the estate. The compensatory levy of Code civil article 913, al. 3 arises only where the applicable foreign law permits no protective reserve mechanism at all, a condition a reserve-type system on the Japanese model is unlikely to meet; the point is assessed on the succession's actual facts.

Has the France–Japan convention ever been tested in court?

At the supreme level, only on its credit article: the Conseil d'État applied the protocol's net-income ceiling to the letter in 2021 (n° 403692), refused any carry-forward of unused credits in 2023 (n° 456349), and in 2021 held unlawful administrative commentary that narrowed a credit beyond the texts (n° 454105). No decision tests the residence or property articles on Japanese facts, and none exists at death — there is no treaty there to construe.

Sources considered: the sections above. Scope note: these answers condense them and inherit their scope notes.

Reviewed as at 10 August 2026

8The court decisions, the sources and the sales figures

The market first, because every figure above traces to it. Read from Tokyo, the coast opens on Cannes: 306 qualified €3M+ villa sales for €2,066M across 2014–2025 in Cannes and its hills alone, at a €4.9M median — the most international of the coast's registers, set between the Saint-Tropez peninsula's broader register (1,006 sales, €7,049M) and the narrower, costlier one at Saint-Jean-Cap-Ferrat (178 sales, €6.5M median). Together the three registers cleared €11.5 billion over twelve years, each line traceable in the state's own transaction data — DVF (« Demandes de Valeurs Foncières », DGFiP), villa sales of €3M and above, 2014–2025, duplicate estate records removed. At this edition the surveyed registers carry no ownership position attributable to Japanese residence — the blank line is worth stating rather than passing over, and the first positions to appear will open the column.

The legal method. Legal statements are verified against the Chiron Legal Corpus — the research library maintained by our agency's offshore legal-research partner — re-checked against the official sources at each edition. The review of 10 August 2026 covered Légifrance (CGI articles 4 B, 150 UB, 150 VC, 167 bis, 197 A, 200 B, 244 bis A incl. IV, 669, 750 ter, 751, 761, 777, 779, 784 A, 964–965, 968, 973–974, 990 D–990 E, 990 J, 1609 nonies G, 1649 AB, 1897; Code civil article 913; LPF article R* 196-1 — consolidated texts), the convention of 3 March 1995 in its official French consolidation — the 2007 avenant and the multilateral instrument incorporated — and the administration's treaty list of 29 April 2026, which records the France–Japan relationship as covering income tax alone. The jurisprudence was read in the decision texts: CE n° 403692, n° 456349, n° 454105 and n° 414463 on the credit machinery, with CJUE Société Générale C-403/19; and CE n° 385737 on the non-resident levy's reclamation window. The July 2026 recency check ran against both authorities' publications — the French administration's Japan page and the Japanese Ministry of Finance treaty list — and found the consolidated 1995 text the latest instrument on both sides.

The consolidation the administration publishes carries no testimonium, so this brief makes no claim about the convention's authentic languages: quotations follow the French text as published at the Journal officiel — an open point our agency records rather than leaves implicit. Japanese domestic law — the inheritance and gift taxes, their residence rules and their unilateral credit — is stated at orientation level from secondary sources and is never load-bearing for a legal claim.

What our agency is watching for the next edition: any first France–Japan succession or gift instrument, which would rewrite § 6 entirely; annual budget law (Loi de finances) movements on the IFI and transfer duties; communal surcharge votes on the Riviera arc; Japanese legislation on inheritance and gift taxation, whose residence rules for foreign nationals have moved repeatedly in recent reforms; any change to either state's reservations under the multilateral instrument; and any refresh of the September 2012 commentary.

This brief documents published law and public transaction data; it is research rather than personalised legal or tax advice, and individual circumstances — residence history, nationality, matrimonial regime, the chain of title — change outcomes. For a live transaction, our agency coordinates the appropriate French counsel (avocat fiscaliste, notaire) and executes the property side.

Reviewed as at 10 August 2026 · decision texts read; DVF register, duplicate estate records removed

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