Tax residence in Japan for Pakistani taxpayers

Japan makes you a resident if your base of life (domicile) is in Japan or you have lived there continuously for one year; a job requiring a stay of a year or more creates a presumption of domicile from arrival. Foreigners with five years or less in Japan within ten years are non-permanent residents, taxed on foreign income only if paid in or remitted to Japan. Pakistan counts its own tax year of 1 July – 30 June. Where both countries claim you, Art. 4(2) of the 2008 Convention decides.

Check your status: Pakistan and Japan

Free, no sign-up, about 3 minutes. Conclusion under Pakistan's Income Tax Ordinance, 2001, compared with the law of Japan and the tax treaty.

When Japan treats you as a tax resident

A resident of Japan is an individual who has a domicile (base of life) in Japan or has had a residence there continuously for one year or more. Nationality matters only for the rule on Japanese public officials and for non-permanent resident status.

A person who takes up an occupation abroad that normally requires living outside Japan continuously for one year or more is presumed to have no domicile in Japan. A company employee transferred abroad for a planned period of a year or more is generally in this position.

Domicile is the base of life, judged by objective facts — housing, occupation, location of assets, where the family lives, nationality. Days of stay alone do not decide it.

A person without Japanese nationality is presumed to have a domicile in Japan from arrival if he or she has an occupation in Japan that normally requires living there continuously for a year or more, and is in any case resident once he or she has had a residence in Japan continuously for one year.

As a Japanese national or local public official you are deemed to have a domicile in Japan even while working abroad (Income Tax Act, Art. 3). You are a resident of Japan and taxed on all income arising in and outside Japan.
Your base of life (domicile) is in Japan. Under Art. 2(1)(iii) of the Income Tax Act you are a resident of Japan (other than a non-permanent resident) and taxed on all income arising in and outside Japan, including income from Pakistan.
You have lived in Japan continuously for a year or more, or are presumed to have a domicile there because your occupation requires living there for a year or more (Income Tax Act, Art. 2(1)(iii); Enforcement Order, Art. 14). You are a resident of Japan and taxed on all income arising in and outside Japan.
You have a domicile in Japan or have lived there for a year or more, you do not have Japanese nationality, and your periods of living in Japan in the past ten years total five years or less — you are a «non-permanent resident» (Income Tax Act, Art. 2(1)(iv)). Japan taxes income other than foreign-source income, and foreign-source income (for example from Pakistan) only to the extent it is paid in Japan or remitted to Japan.
You have a domicile in Japan or have lived there for a year or more, and your periods of living in Japan in the past ten years exceed five years — you are a resident other than a non-permanent resident. Even without Japanese nationality, Japan taxes all your income arising in and outside Japan.
You are a resident of Japan. If your periods of living in Japan in the past ten years total five years or less, you are a non-permanent resident (foreign-source income taxed only if paid in or remitted to Japan); if more, all your income is taxed. Check the period from your dates of entry and departure.

When you are a nonresident

Your occupation outside Japan normally requires you to live abroad continuously for a year or more, so you are presumed to have no domicile in Japan (Enforcement Order, Art. 15). As a non-resident you are taxed in Japan only on Japan-source income. The presumption can be rebutted by the facts.
Your base of life (domicile) is not in Japan and you have not lived there continuously for a year or more. As a non-resident you are taxed in Japan only on Japan-source income (Income Tax Act, Art. 2(1)(v) and Art. 7).

Where the rules of Japan clash with Pakistani tax rules

Collision: Pakistani citizen resident in both countries. Under s. 82(d) of the Income Tax Ordinance a Pakistani citizen stays resident in Pakistan unless present in one other country for more than 182 days in the Pakistani tax year and a resident taxpayer there. Japan can make you resident from the day you arrive (domicile presumed for a job of a year or more) or after one year of residence, while your days in Japan in a Pakistani tax year are still 182 or fewer — typically in the year of arrival or departure. Then Art. 4(2) of the Pakistan–Japan Convention decides: permanent home; if a home in both — centre of vital interests; if that cannot be determined or you have no permanent home in either — habitual abode; then nationality; then mutual agreement.
Resident of both countries: Art. 4(2) and certificates of residence. If both countries treat you as resident, Art. 4(2) of the Convention assigns you to one of them. Japan issues a certificate of residence through the competent tax office (two copies with a request form); Pakistan issues one through the Competent Authority (FBR) under rule 19A. If the criteria give no answer, the competent authorities settle the case by mutual agreement; a case must be presented within three years from the first notification of the taxation (Art. 25(1)).

What else to know

Different tests and years: domicile in Japan, days in Pakistan. Japan does not count days: you are resident if your base of life is in Japan or you have lived there continuously for a year — a Pakistani who comes to Japan on a contract of a year or more is presumed domiciled from arrival. Japan's tax year is the calendar year; Pakistan counts days in its tax year (1 July – 30 June). The treaty's 183-day employment test (Art. 16(2)(a)) uses any 12-month period commencing or ending in the tax year concerned.
Non-permanent resident: Pakistani income taxed in Japan only if paid or remitted there. Without Japanese nationality and with five years or less of living in Japan in the past ten years, you are a non-permanent resident. Foreign-source income — for example rent from Pakistan or profit on Pakistani deposits — is taxed in Japan only if it is paid in Japan or remitted to Japan; the foreign tax credit covers only that part. Non-permanent residents do not file the statement of foreign assets. Pakistan may still tax that income if you are resident there.
Working in Japan while resident in Pakistan. If you are a treaty resident of Pakistan, Japan does not tax your pay for work in Japan only if all three conditions of Art. 16(2) are met: no more than 183 days in Japan in any 12-month period commencing or ending in the tax year concerned, an employer that is not resident in Japan, and pay not borne by a Japanese permanent establishment. Otherwise Japan withholds 20.42% from a non-resident's pay for work in Japan. In Pakistan, salary earned in Japan is exempt if Japanese tax on it was withheld by the employer and paid (s. 102); otherwise Pakistan deducts the Japanese tax, up to the Pakistani tax on that income (Art. 23(2)(a); s. 103).
How double tax is relieved between Pakistan and Japan. If you are a treaty resident of Japan, Pakistani tax on income from Pakistan is credited against Japanese tax up to the Japanese tax on that income (Art. 23(1)(a)); under Art. 95 of the Income Tax Act unused limits and excess tax carry forward for three years. If you are a treaty resident of Pakistan, Japanese tax is deducted from Pakistani tax up to the Pakistani tax on the same income (Art. 23(2)(a)), and income taxable only in Japan may be counted only to set your Pakistani rate (Art. 23(2)(b)). The Convention has no tax-sparing credit.
Pakistani government posting to Japan. Federal and Provincial Government employees and officials posted abroad remain resident in Pakistan under s. 82(c). Under the government-service article (Art. 20) of the Convention, their government salary is generally taxable only in Pakistan; the article contains exceptions, for example for locally engaged staff who are Japanese nationals.
Year of arrival or departure: Japan splits the year, Pakistan does not. Japan taxes the year of arrival or departure in two parts: as a resident from the day residence starts (or until it ends), and as a non-resident only on Japan-source income for the rest. Individual inhabitant tax is charged where you have a domicile on 1 January. Pakistan has no split year: status is fixed for the whole 1 July – 30 June tax year. A Pakistani citizen who leaves Pakistan during a tax year and stays abroad for the rest of it is exempt in Pakistan on salary earned abroad in that year (s. 51(2)).
Leaving Japan with securities of ¥100 million or more: exit tax. If you hold securities and similar assets worth ¥100 million or more when you leave Japan and lived there for more than five of the past ten years, Japan taxes the unrealised gains as if sold on departure (Art. 60-2). Payment can be deferred for five years (up to ten) with a tax agent and collateral, and the tax is cancelled if you return within that period.
Social security: no Pakistan–Japan agreement. Japan has no social security agreement with Pakistan (Japan Pension Service list of agreements in force). A worker in Japan generally joins Japanese pension and health insurance, and periods are not totalised with Pakistani schemes. Social security is outside the income tax treaty.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Convention between the Islamic Republic of Pakistan and Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (signed at Islamabad on 23 January 2008). The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

Terms you will come across in Japan

住所 (jūsho, domicile): the base of a person's life in Japan, judged by housing, work, family and assets
居所 (kyosho, residence): a place where a person actually lives without it being the base of life; one year of continuous residence makes you resident
非永住者 (non-permanent resident): a resident without Japanese nationality with five years or less in Japan in the past ten years
年末調整 (year-end adjustment): the employer's annual settlement of withheld income tax
確定申告 (final return): the income tax return filed between 16 February and 15 March
住民税 (inhabitant tax): local tax of about 10% charged where you have a domicile on 1 January

Questions

Which tax treaty applies between Pakistan and Japan?

The Convention signed at Islamabad on 23 January 2008, in force since 9 November 2008, which replaced the 1959 Convention. The MLI applies to it but did not change Art. 4(2), the tie-breaker for individuals.

I am sent to Tokyo for 8 months. Does Japan tax my salary?

With an assignment of less than a year and no base of life in Japan you are usually a non-resident. Japan then taxes pay for work in Japan unless Art. 16(2) applies: no more than 183 days in any 12-month period, an employer not resident in Japan, and pay not borne by a Japanese establishment.

Is there a social security agreement between Pakistan and Japan?

No. Pakistan is not on the Japan Pension Service list of agreements in force, so each country applies its own contribution rules.

Sources

Legislation and official guidance

Income Tax Act (Japan), Art. 2(1)(iii)–(v) — Resident: an individual who has a domicile (jūsho) in Japan or has had a residence (kyosho) in Japan continuously for one year or more up to the present. Non-permanent resident: a resident who does not have Japanese nationality and has had a domicile or residence in Japan for an aggregate of five years or less within the past ten years. Non-resident: any individual other than a resident.
Income Tax Act (Japan), Art. 3 — National and local public officials (excluding those without Japanese nationality and others prescribed by Cabinet Order) are deemed to have a domicile in Japan even for periods in which they have no domicile there.
Order for Enforcement of the Income Tax Act, Art. 15 — An individual who has come to live abroad is presumed to have no domicile in Japan if (1) he or she has an occupation that normally requires living abroad continuously for one year or more, or (2) he or she has foreign nationality or foreign permanent residence and no family in Japan sharing a livelihood, or other facts indicating a return to live mainly in Japan. Family members living with and sharing the person's livelihood are treated the same.
National Tax Agency (NTA), Tax Answer No. 1926 (as of 1 April 2026) — An employee of a Japanese company transferred to a branch abroad for a planned period of one year or more is generally presumed to have no domicile in Japan and becomes a non-resident. In the year of departure, if a tax agent is appointed, all income of the resident period and Japan-source income of the non-resident period are declared between 16 February and 15 March of the next year; without a tax agent, a quasi-final return is filed by the time of departure. Rent from Japanese real estate is generally subject to 20.42% withholding.
Basic Circular on the Income Tax Act (Japan), 2-1 to 2-4 — Domicile means the base of a person's life, determined by objective facts (2-1). Where the purpose of going abroad is clearly temporary (spouse left in Japan, a house kept for use after return, etc.), the person is treated as keeping a residence in Japan while abroad (2-2). A person without a domicile who has entered Japan is a non-resident until the day one year after entry and a resident from the following day (2-3); the one-year period is counted from the day after entry (2-4).
National Tax Agency (NTA), Tax Answer No. 2012 (as of 1 April 2026) — Whether the base of life is in Japan is judged by objective facts such as housing, occupation, location of assets, where relatives live and nationality — not by days of stay alone, so a person can be resident in Japan even after staying 183 days or more abroad. If a person becomes resident in both countries, the tax treaty decides, with mutual agreement between the authorities where necessary.
Order for Enforcement of the Income Tax Act, Art. 14 — An individual who has come to live in Japan is presumed to have a domicile in Japan if (1) he or she has an occupation that normally requires living in Japan continuously for one year or more, or (2) he or she has Japanese nationality and a spouse or other relatives in Japan sharing a livelihood, or other facts indicating continuous residence in Japan for one year or more. Family members living with and sharing the person's livelihood are treated the same.
Income Tax Act (Japan), Arts. 5 and 7; NTA Tax Answer No. 2010 — Residents other than non-permanent residents are taxed on all income arising in and outside Japan. Non-permanent residents are taxed on income other than foreign-source income and on foreign-source income paid in Japan or remitted to Japan from abroad. Non-residents are taxed only on Japan-source income.
Income Tax Ordinance, 2001, s. 82(a) — An individual is a resident individual for a tax year if present in Pakistan for a period of, or periods amounting in aggregate to, 183 days or more in the tax year (1 July – 30 June).
Art. 16(2) Pakistan–Japan Convention (2008) — Remuneration of a resident of one State for employment exercised in the other State is taxable only in the residence State if the recipient is present in the other State for periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the tax year or taxable year concerned, the remuneration is paid by or on behalf of an employer who is not a resident of the other State, and it is not borne by a permanent establishment or fixed base of the employer in the other State.
Income Tax Ordinance, 2001, s. 82(d) (inserted by the Finance Act, 2022; consolidated text amended up to 30.06.2026 listed by FBR) — A citizen of Pakistan is also a resident individual if he or she is not present in any other country for more than 182 days during the tax year, or is not a resident taxpayer of any other country. Applies from tax year 2023.
Art. 4(2) Pakistan–Japan Convention (2008) — Dual-resident individual: (a) resident only of the State where he has a permanent home available to him; if he has one in both States — the State with which his personal and economic relations are closer (centre of vital interests); (b) if that State cannot be determined, or if he has no permanent home available in either State — the State of his habitual abode; (c) habitual abode in both or neither — the State of which he is a national; (d) national of both or neither — mutual agreement.
National Tax Agency (NTA), Tax Answer No. 9210 — Request for a certificate of residence — A certificate that the person is a resident of Japan, needed for treaty relief abroad, is issued by the competent tax office on a request form with two copies of the certificate, by post or in person; the other country's form is used if it has one.
Income Tax Rules, 2002, rule 19A — A resident who needs a certificate of residence for a treaty country applies to the Competent Authority of Pakistan (FBR, Islamabad) in the prescribed form with proof of foreign income, CNIC, NTN and the latest return; a separate application and certificate for each tax year; decision within 45 days.
Income Tax Act (Japan), Art. 95; NTA Tax Answer No. 1240 — A resident paying foreign income tax may deduct it from Japanese income tax up to a limit (income tax × adjusted foreign income ÷ total income), and the excess up to the limit for the special reconstruction income tax. Unused limits and excess foreign tax can be carried forward for three years. For non-permanent residents, foreign income is limited to amounts paid in or remitted to Japan. Tax above a treaty's limit rate is not creditable. The return must include the statement on the foreign tax credit and evidence of the foreign tax.
Act on Submission of Statement of Overseas Remittance, Art. 5; NTA Tax Answer No. 7456 — A resident (other than a non-permanent resident) holding foreign assets worth more than ¥50 million in total on 31 December must submit a statement of foreign assets by 30 June of the following year.
Income Tax Act (Japan), Arts. 161, 212 and 213; NTA Tax Answer No. 2884 — A payer of Japan-source income to a non-resident withholds tax: 20.42% on salaries and other remuneration for personal services, retirement allowances, real estate rent, loan interest and royalties; 15.315% on dividends and interest of listed shares. Treaty reductions require the «Application Form for Income Tax Convention» to be submitted through the payer by the day before payment.
Income Tax Ordinance, 2001, s. 102 — Foreign-source salary received by a resident individual is exempt if the individual has paid foreign income tax on it; tax is treated as paid if it was withheld by the employer and paid to the revenue authority of the country where the employment was exercised.
Art. 23 Pakistan–Japan Convention (2008) — Japan: Pakistan tax on income from Pakistan that may be taxed there under the Convention is credited against Japanese tax, up to the Japanese tax appropriate to that income (para. 1(a)). Pakistan: Japanese income tax on income that may be taxed in Japan is deducted from Pakistani tax, up to the Pakistani tax on the same income at Pakistani rates (para. 2(a)); income taxable only in Japan may be included in the Pakistani tax base only to determine the rate (para. 2(b)).
Income Tax Ordinance, 2001, s. 103 — A resident taxpayer gets a credit for foreign income tax on foreign-source income equal to the lesser of the foreign tax paid and the Pakistan tax on that income (average Pakistani rate × net foreign-source income), computed separately for each head of income; unused credit is not refunded, carried back or forward; the foreign tax must be paid within two years after the end of the tax year.
Income Tax Ordinance, 2001, s. 82(c) — An individual is a resident individual for a tax year if he or she is an employee or official of the Federal Government or a Provincial Government posted abroad in the tax year — regardless of days in Pakistan.
Art. 20 Pakistan–Japan Convention (2008) — government service — Remuneration (other than pensions) paid by a Contracting State or its political subdivision or local authority to an individual for services rendered in the discharge of governmental functions is taxable only in that State, subject to the exceptions in the article.
Ministry of Internal Affairs and Communications — Individual inhabitant tax — Individual inhabitant tax is imposed on persons with a domicile in a municipality on 1 January of the year: 10% income levy (4% prefectural, 6% municipal) on the previous calendar year's income plus a flat per-capita levy; for employees it is usually deducted from salary.
Income Tax Ordinance, 2001, s. 51 — (1) A citizen who becomes resident in a tax year after being non-resident in the four preceding tax years: foreign-source income is exempt in that tax year and the following one. (2) A citizen who leaves Pakistan during a tax year and remains abroad for the rest of it: salary earned outside Pakistan in that year is exempt.
Income Tax Act (Japan), Art. 60-2; NTA Tax Answer No. 1478 — A resident who at departure holds securities and similar assets worth ¥100 million or more and had a domicile or residence in Japan for more than five years in total within the ten years before departure is taxed on the unrealised gains (exit tax). Payment can be deferred for five years (up to ten with extension) with a tax agent and collateral; the tax can be cancelled on return within that period (request within four months of return).
Japan Pension Service — Social security agreements (updated 27 October 2025) — Agreements in force: Germany, the UK, Korea, the USA, Belgium, France, Canada, Australia, the Netherlands, the Czech Republic, Spain, Ireland, Brazil, Switzerland, Hungary, India, Luxembourg, the Philippines, Slovakia, China, Finland, Sweden, Italy and Austria (in force 1 December 2025). Pakistan is not on the list.
Income Tax Act (Japan), Art. 89; NTA Tax Answer No. 2260 — Seven brackets on taxable income: 5% (under ¥1.95 million), 10% (under ¥3.3 million), 20% (under ¥6.95 million), 23% (under ¥9 million), 33% (under ¥18 million), 40% (under ¥40 million), 45% (¥40 million or more). For 2013–2037, special reconstruction income tax of 2.1% of the basic income tax is payable in addition.
Income Tax Act (Japan), Arts. 120–121; NTA Tax Answer No. 1900 — Most employees settle their tax through year-end adjustment and need not file. A final return is required, among others, by those with annual salary above ¥20 million, other income above ¥200,000, or salary from a payer not obliged to withhold Japanese tax.
Ministry of Finance (Japan) — MLI and the Japan–Pakistan Convention — Convention signed 23 January 2008, in force 9 November 2008. MLI in force for Japan 1 January 2019 and for Pakistan 1 April 2021; applied provisions: MLI Arts. 4(1) (dual-resident entities only), 6, 7, 9(4), 10, 12, 13(2) and (4), 15, 16(1) first sentence, 17(1). Art. 4(2) of the Convention (individuals) is not changed.
Japanese text of the Pakistan–Japan Convention (MOFA treaty database) — Authentic Japanese text: entry into force on the thirtieth day after the exchange of diplomatic notes; applies in Japan from 1 January and in Pakistan (taxes not withheld at source) from tax years beginning on or after 1 July of the year after entry into force; the 1959 Convention ceases to have effect.
Art. 4(2)(b) Pakistan–Japan Convention (2008) — If the State of the centre of vital interests cannot be determined, or if the individual does not have a permanent home available in either State, he is deemed a resident only of the State in which he has an habitual abode (the centre of vital interests step applies only where there is a home in both States).
Art. 4(2) Pakistan–Japan Convention (2008)(a) — Centre of vital interests: the State with which your personal and economic relations are closer.
Art. 4(2)(c)–(d) Pakistan–Japan Convention (2008) — Habitual abode in both States or in neither — resident only of the State of which he is a national; national of both or of neither — the competent authorities settle the question by mutual agreement (Art. 25).

Case law

Supreme Court of Japan, Second Petty Bench, 平成20年(行ヒ)第139号, 18/02/2011 — Gift tax case on the meaning of «domicile» (former Inheritance Tax Act, Art. 1-2(1)). A person posted to Hong Kong who spent about two-thirds of the period there was held to have no domicile in Japan at the time of the gift, although he spent about a quarter of the period in Japan, also working there, and adjusted his days in Japan to avoid tax. A tax-avoidance motive alone does not place a person's domicile in Japan.

Updated 04/11/2026. The result is for information only and is not tax or legal advice. The FBR, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes with each Finance Act. Consult a qualified adviser before making decisions.

Check your status