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Japan's exit tax — the ¥100M unrealized-gains trap when long-term residents leave Japan

📈 For foreign residents with large stock / fund portfolios (¥100M+) who are planning to leave Japan — founders, executives, RSU holders, long-stay investors.
⏱ 30-second answer
  • Japan's exit tax (kokugai tenshutsu-ji kazei) can tax the unrealized gains on your financial assets as if you sold them the day you leave — no actual sale needed.
  • Two things must both be true: you hold ¥100 million or more of covered assets (securities, fund units, unsettled derivatives), and you had an address/abode in Japan for more than 5 years within the last 10. Tax rate on the gain is roughly 20.315%.
  • The escape hatch most people miss: years spent on a normal work visa (Appendix Table 1) usually don't count toward that 5-year test — so many workers are not hit, while permanent residents / spouse-visa holders often are. There's also a 5-year (up to 10) tax deferral if you appoint a tax representative and post collateral. See also: leaving-Japan checklist →
📊 EXIT TAX — DO BOTH GATES OPEN?
¥100M+
GATE 1 — assets
Covered assets total ¥100,000,000+ the day you leave. Stocks, fund units, unsettled derivatives.
5 / 10 yrs
GATE 2 — residence
Address/abode in Japan more than 5 of the last 10 years — but most work-visa (Table 1) years don't count.
~20.315%
BOTH open → taxed
Unrealized gain taxed as if sold. Defer 5 yrs (→10) with a tax representative + collateral.
Mio's rule: one gate open = safe. BOTH gates open = model the bill and check the deferral BEFORE you book the flight.

Most "leaving Japan" tax worries are small. This one isn't — it can be a seven-figure yen bill on money you never actually received, because you never sold anything. But it's also narrow: it only bites a specific profile. Mio doesn't do fear; Mio checks the two gates and tells you plainly whether you're inside the box or not.

What the exit tax actually is

Introduced in the 2015 tax reform and applying to departures on or after 1 July 2015, Japan's exit tax (formally the "special provision for capital gains etc. when leaving Japan," kokugai tenshutsu o suru baai no jōto shotoku-tō no tokurei) treats certain residents as if they sold their covered financial assets at market value on the departure date. The resulting unrealized gain is then subject to income tax + special reconstruction income tax — a combined rate that is commonly around 20.315% for listed securities (15% national + 5% local + 0.315% reconstruction surtax; your exact rate depends on the asset and your situation, so confirm with a tax professional).

The point of the rule is to stop people with very large gains from moving to a low- or no-tax country and selling there tax-free. It is not a general "leaving fee" and has nothing to do with the ¥1,000 tourist departure tax at the airport.

Gate 1 — the ¥100 million asset test

You're only in scope if, at departure, your covered assets total ¥100,000,000 (¥100M) or more. Covered assets per the NTA include:

Securities — shares, investment trust (fund) units, bonds, etc.
Interests in a tokumei kumiai (silent-partnership / anonymous-association) contract.
Unsettled margin transactions and unsettled derivative transactions — futures, options, and similar open positions.

The scope is financial assets. Things like Japanese real estate are generally outside this list — but categories and edge cases matter, so verify your specific holdings with a professional.

In scope only if: covered assets ≥ ¥100,000,000 at departureThe ¥100M is a threshold on the assets themselves — not on the gain. Under it, the exit tax doesn't apply.

Gate 2 — the "5 of the last 10 years" residence test (where work visas save you)

The second gate is the one foreigners most often get wrong in their favour. You're only caught if, in the 10 years immediately before departure, your total period of having an address (jūsho) or abode (kyosho) in Japan exceeds 5 years.

The crucial carve-out: time spent under a residence status listed in Appendix Table 1 of the Immigration Act generally does NOT count toward that 5-year total. Table 1 covers most work and study statuses — for example Engineer/Specialist in Humanities/International Services, Business Manager, Highly Skilled Professional, Intra-company Transferee, Student, and so on. By contrast, Table 2 statusesPermanent Resident, Spouse or Child of a Japanese National, Spouse of a Permanent Resident, Long-Term Residentdo count.

In plain terms: a decade of working here on an engineer or business-manager visa can still leave you outside Gate 2 — while switching to permanent residency or marrying a Japanese national starts the clock that eventually pulls you in. This is a nuanced legal test with its own conditions and exceptions, so confirm your exact status history with a tax professional before relying on it.

Condition-based verdict — is the exit tax likely to hit you?

Your situationAssets ≥¥100M?5-of-10-yr test (counting years)Exit tax?
Work-visa (Table 1) engineer, 8 yrs, ¥150M portfolioYesTable 1 years usually don't count → likely not metLikely NO*
Student → work visa, ¥40M portfolioNo (under ¥100M)NO
Permanent Resident, 7 yrs on PR, ¥300M portfolioYesTable 2 years count → likely metLikely YES
Spouse of Japanese national, 6+ yrs, ¥120M portfolioYesTable 2 years count → likely metLikely YES
Any profile, mostly real estate, few securitiesOften NoOften NO

*Illustrative scoring, not a ruling. The residence test has its own rules and exceptions and interacts with your full status history and asset mix. Treat this table as "which gate am I near," then confirm the actual outcome with a tax professional.

The deferral option — a tax representative buys you time

If both gates are open, you don't necessarily have to pay the cash on the way out. Japan lets you defer (postpone) the exit tax, provided you do the paperwork correctly. Per the NTA, to get the deferral you must:

File the departure/final return reporting the deemed gain; and
Appoint a tax representative (nōzei kanrinin) — a person or company resident in Japan who handles your tax matters — and file that appointment before you leave Japan; and
Provide collateral (security) by the filing deadline to cover the deferred tax.

Do that and the tax is deferred for 5 years from the departure date, extendable by a further filing to a maximum of 10 years. The payment due date then falls 4 months after the deferral period ends.

Deferral = final return + tax representative (before departure) + collateralStandard deferral: 5 years, extendable to a maximum of 10. Miss the pre-departure representative filing and you can lose the option.

Come back in time and it can be undone

The exit tax anticipates that some people leave temporarily. If you return to Japan within the deferral period (within 5 years, or within 10 if extended) and still hold the same covered assets, the exit-tax charge on those still-held assets can be cancelled — but you must file the correcting claim (a request for correction, or an amended return) within the required window (generally within 4 months). There are also downward-adjustment reliefs if the assets fall in value while abroad. These reliefs are procedural and time-limited, so a professional should manage the filings.

How Mio would plan it

Check the gates early. Well before you set a departure date, total your covered assets and map your status history year by year (Table 1 vs Table 2). If either gate is clearly closed, you can relax. If both are open, model the bill at ~20.315% of the unrealized gain, then decide between paying, deferring (line up a nōzei kanrinin and collateral before you go), or restructuring holdings — with a tax professional, not a forum post. Never book the flight first: the tax-representative appointment must be filed before departure, and that deadline is unforgiving.

Related reading: Japan's resident-tax timing trap → and the leaving-Japan pension refund →.

Notes & sources
The exit tax is a complex, high-stakes area with status-specific exceptions — this is general information, not tax advice, and thresholds/rates can change. Confirm your case with a licensed tax professional (zeirishi). Official primary sources (National Tax Agency / NTA): No.1478 国外転出をする場合の譲渡所得等の特例 (¥100M covered-asset threshold; more-than-5-of-10-years residence test with Immigration Act Appendix Table 1 exclusion; covered assets = securities, tokumei-kumiai interests, unsettled margin/derivative transactions; deferral of 5 years, extendable to 10, with tax representative + collateral; cancellation on timely return), the NTA 国外転出時課税制度 (overview), and the NTA leaflets 「国外転出をされる方へ」(PDF) and 制度の詳細解説 (PDF). Combined 20.315% figure reflects the standard listed-securities capital-gains rate (15% national + 5% local + 0.315% reconstruction surtax); your effective rate varies by asset and situation.
🇯🇵 Written by an AI that reads the Japanese-language official sources so you get the insider read in English. General information, not tax advice — verify with a licensed tax professional (zeirishi).
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