Tax residence in Japan for Singapore taxpayers

Japan has no day test: you are resident if your domicile — the base of your life — is in Japan or you have lived there for one year or more, and a job of a year or more makes you resident from arrival. A foreigner resident for 5 years or less in the past 10 is a non-permanent resident, taxed on foreign income only if it is paid in or remitted to Japan. If Singapore also treats you as resident, Art. 4(2) of the Singapore–Japan Agreement decides, starting with the centre of vital interests rather than a permanent home.

Check your status: Singapore and Japan

Free, no sign-up, about 3 minutes. Conclusion under Singapore's Income Tax Act 1947, compared with the law of Japan and the tax treaty (DTA).

When Japan treats you as a tax resident

A Japanese resident is an individual with a domicile (the base of life) in Japan or with a residence in Japan continuously for one year or more. Japan has no day-count test. Nationality matters only for the deeming rule for public servants and for the non-permanent resident category.

A person who takes up an occupation abroad that normally requires living abroad continuously for one year or more is presumed not to have a domicile in Japan. An employee transferred to an overseas branch — for example in Singapore — for a planned year or longer generally falls under this rule.

Domicile is the base of your life, determined by objective facts — residence, occupation, location of assets, where your relatives live, nationality — and not by the number of days alone.

A person without Japanese nationality who takes up an occupation in Japan that normally requires living there for one year or more is presumed to have a domicile in Japan; a person who has had a residence in Japan continuously for one year or more is also resident.

As a Japanese national or local public servant you are deemed to have a domicile in Japan even while working abroad without one (Income Tax Act art. 3). You are a Japanese resident taxed on all income arising in and outside Japan.
The base of your life (domicile) is in Japan. Under art. 2(1)(iii) of the Income Tax Act you are a Japanese resident (not a non-permanent resident) taxed on all income arising in and outside Japan.
You have lived in Japan continuously for one year or more, or you are presumed to have a domicile there because your occupation requires living in Japan for one year or more (art. 2(1)(iii) of the Income Tax Act; Enforcement Order art. 14). You are a Japanese resident taxed on all income arising in and outside Japan.
You have a domicile in Japan or have lived there for one year or more, you do not have Japanese nationality, and your total time of domicile or residence in Japan in the past 10 years is 5 years or less, so you are a «non-permanent resident» (art. 2(1)(iv)). Japan taxes your income other than foreign-source income, and foreign-source income — for example from Singapore — only if it is paid in Japan or remitted to Japan.
You have a domicile in Japan or have lived there for one year or more, and your total time of domicile or residence in Japan in the past 10 years exceeds 5 years, so 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 Japanese resident. If your total time of domicile or residence in Japan in the past 10 years is 5 years or less, you are a non-permanent resident (foreign-source income taxed only if paid in Japan or remitted there); if it exceeds 5 years, all income is taxable. Check the periods from your entry and departure dates.

When you are a non-resident

You have an occupation abroad that normally requires living outside Japan continuously for one year or more, so you are presumed not to have a 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.
The base of your life is not in Japan and you have not lived there continuously for one year or more. As a non-resident you are taxed in Japan only on Japan-source income (Income Tax Act art. 2(1)(v), art. 7).

Where the rules of Japan clash with Singapore tax rules

Resident of both countries: the Singapore–Japan Agreement starts with the centre of vital interests. If Japan and Singapore both treat you as resident, Art. 4(2) of the Agreement does not ask first where you have a permanent home: it looks directly at the country with which your personal and economic relations are closest (centre of vital interests); if that cannot be determined, at your habitual abode; then at nationality; and if you are a national of both or neither, the competent authorities decide by mutual agreement. Keep evidence of your family, work, assets and days in each country.
Collision: Japanese residence from arrival for a job of a year or more. If you come to Japan for an occupation that normally requires living there for one year or more, Japan presumes a domicile in Japan from your arrival — there is no minimum number of days (Enforcement Order art. 14). Singapore decides your status for the whole calendar year: in the year you leave you stay resident there with 183 days of presence or employment before departure, or as a foreign employee under the IRAS two-year rule. For the overlapping months both countries treat you as resident, and Art. 4(2) of the Agreement decides, starting with the centre of vital interests.

What else to know

No day test in Japan; the calendar year in both countries. Japan has no day-count test: you are resident if the base of your life (domicile) is in Japan or you have lived there continuously for one year or more, and Japanese income tax is computed for the calendar year. Singapore also decides residence for the calendar year — the basis period of the following Year of Assessment — mainly by 183 days of presence or employment, or by normal residence for citizens and permanent residents. The 183-day limit for salary in Art. 15(2)(a) of the Singapore–Japan Agreement is counted in any consecutive twelve-month period, not per tax year.
Non-permanent resident: income from Singapore taxed in Japan only if paid or remitted there. As a non-permanent resident of Japan you are taxed there on foreign-source income — for example salary for work done in Singapore, rent from Singapore property or interest on Singapore accounts — only to the extent that it is paid in Japan or remitted to Japan; the foreign tax credit is limited to that part too. Once your domicile or residence in Japan exceeds 5 years in total within 10 years, Japan taxes your worldwide income.
How Singapore relieves double taxation of Japanese income. If Singapore is your state of residence, it generally does not tax your Japanese income: foreign-sourced income not brought into Singapore is outside the charge (s. 10(1) ITA 1947), and foreign-sourced income received in Singapore by a resident individual is exempt (s. 13(7A)), except through a partnership in Singapore. Where Japanese income is taxable in Singapore, the Japanese tax is credited (Art. 23(2)) — at most the Singapore tax on that income. Because of the remittance clause (Art. 22(1)), a Japanese treaty reduction may cover only the amount remitted to Singapore. If Japan is your state of residence, Japan credits Singapore tax under its foreign tax credit rules (Art. 23(1); art. 95: credit limit, 3-year carry-forward).
Working in Japan while resident in Singapore: the 183-day rule (Art. 15(2)). Pay for work physically done in Japan is Japan-source. If Singapore is your treaty residence, Japan does not tax it only if all three conditions of Art. 15(2) are met: you are in Japan for not more than 183 days in aggregate in any consecutive twelve-month period; the employer is not resident in Japan; and the pay is not borne by a permanent establishment or fixed base of the employer in Japan. Otherwise Japan withholds or assesses tax on the pay for your Japan work days.
Leaving Japan for Singapore: non-resident from the day after departure. If you are transferred to Singapore for a year or more, Japan presumes that you have no domicile in Japan (Enforcement Order art. 15) and you are usually a non-resident from the day after departure. For the year of departure you declare all income up to departure plus Japan-source income afterwards — by 15 March of the next year if you appointed a tax agent, otherwise by the time you leave. The inhabitant tax is charged by the municipality where you lived on 1 January, so it is due for the year you leave. Afterwards Japan taxes only Japan-source income; as a Singapore resident you are taxed in Singapore on Singapore-source income, and foreign-sourced income is generally not taxed there.
Year of arrival or departure: Japan splits the year into resident and non-resident periods, Singapore does not. Japanese residence starts when you acquire a domicile in Japan — for a job of a year or more, from arrival — or on the day after one year of residence, and ends on departure; the income of that year is divided into a resident period and a non-resident period. Singapore has no split year: your status is decided for the whole calendar year. Overlapping periods of residence are settled under Art. 4(2) of the Agreement.
Japanese exit tax: leaving with securities of ¥100 million or more. If, when you leave Japan, you hold securities etc. worth ¥100 million or more and had a domicile or residence in Japan for more than 5 years in the 10 years before departure, Japan taxes the unrealised gains as if you had sold them (Income Tax Act art. 60-2). Payment can be deferred for 5 years (up to 10) if you appoint a tax agent and provide security, and the tax is cancelled if you return within that period. Singapore generally does not tax gains from selling shares unless the sale amounts to trading, so there is usually no Singapore tax on a later sale against which the Japanese tax could be credited.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Agreement between the Government of the Republic of Singapore and the Government of Japan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (signed at Singapore on 9 April 1994), with Protocol and Exchange of Notes, as amended by the Protocol of 4 February 2010 and modified by the MLI. The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

The treaty in detail: income, rates, the 183-day rule →

Terms you will come across in Japan

jūsho (domicile): the base of your life in Japan, judged by home, work, family, assets and nationality
kyosho (residence): a place where you actually live that is not the base of your life; one year of it makes you resident
non-permanent resident (hi-eijūsha): a non-Japanese resident with 5 years or less in Japan in the past 10 years: foreign income taxed only if paid in or remitted to Japan
year-end adjustment (nenmatsu chōsei): the employer's annual settlement of tax withheld from salary
inhabitant tax (jūminzei): local income tax of about 10%, charged where you live on 1 January
nōzei kanrinin: tax agent a non-resident appoints to deal with Japanese returns

Questions

Am I resident in Japan from the day I arrive?

If you come for an occupation that normally requires living in Japan for a year or more, Japan presumes a domicile from arrival. Otherwise you become resident once you have lived there for one year.

How is dual residence resolved under the Singapore–Japan Agreement?

Art. 4(2) looks first at the country with which your personal and economic relations are closest, then at your habitual abode, then at nationality; if you are a national of both or neither, the competent authorities decide by mutual agreement.

Does Japan tax my salary for a short Japan assignment?

Not if all conditions of Art. 15(2) are met: not more than 183 days in any consecutive twelve-month period, an employer not resident in Japan, and pay not borne by a Japanese permanent establishment.

Sources

Legislation and official guidance

Income Tax Act (Japan), art. 2(1)(iii)–(v) — Resident: an individual who has a domicile in Japan, or who has had a residence 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 a total of 5 years or less within the past 10 years. Non-resident: an individual other than a resident.
Income Tax Act (Japan), art. 3 — National and local public servants (excluding those without Japanese nationality and others specified by Cabinet Order) are deemed to have a domicile in Japan even for periods in which they have no domicile in Japan. Matters needed to determine domicile are prescribed by Cabinet Order.
Order for Enforcement of the Income Tax Act, art. 15 — An individual who has come to live outside Japan is presumed not to have a 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 a foreign nationality or foreign permanent residence permit and there are no facts — such as relatives sharing living expenses in Japan — suggesting a return to live mainly in Japan. Family members living with that person and sharing living expenses are treated the same.
NTA Tax Answer No. 1926 (law as of 1 April 2026) — An employee of a Japanese company transferred to an overseas branch for a planned period of one year or more is generally presumed not to have a 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 following year; without a tax agent, a final return is filed by the time of departure. Rent from Japanese real estate is in principle subject to 20.42% withholding.
Basic Circular on Income Tax 2-1 to 2-4 — Domicile means the base of a person's life and is determined by objective facts (2-1). Where the purpose of going abroad is clearly temporary (a spouse left in Japan, a home kept for living in after return, etc.), the person is treated as keeping a residence in Japan while abroad (2-2). A person with no domicile on entry is a non-resident until the day one year after entry and a resident from the following day (2-3). The «one year» is counted from the day after the day of entry (2-4).
NTA Tax Answer No. 2012 (law as of 1 April 2026) — Whether the base of life is in Japan is decided by objective facts such as residence, occupation, location of assets, where relatives live and nationality. It is not decided by days of stay alone, so a person can be a Japanese resident even after staying abroad for 183 days or more. A person resident of both countries is assigned by the tax treaty, 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 sharing living expenses in Japan, or other facts suggesting continuous residence in Japan for one year or more. Family members living with that person and sharing living expenses 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 from abroad. Non-residents are taxed only on Japan-source income.
s. 2(1) ITA 1947 (definitions of «year of assessment» and «basis period»); IRAS — preceding-year basis of assessment — Tax is charged for a year of assessment (YA) on the income of the preceding calendar year: YA 2027 covers income from 1 January to 31 December 2026. Residence is determined for the same preceding calendar year, so the selected year 2026 is the basis year for YA 2027.
IRAS — «Working out my tax residency» (updated 12 May 2026) — A Singapore citizen or permanent resident who normally resides in Singapore, except for temporary absences, is a tax resident. A foreigner is resident for a year of assessment if, in the preceding calendar year, he or she stayed or worked in Singapore for at least 183 days, or stays or works in Singapore continuously for three consecutive years (then for all three years, even with fewer than 183 days in the first and third). A foreign employee whose employment spans two calendar years is resident for both years if the period of employment, together with the stay immediately before and after it, is a continuous period of at least 183 days (not for company directors, public entertainers and professionals). Days include weekends and public holidays, and temporary absences (leave abroad, business trips) connected with the employment in Singapore.
Art. 15(2) of the Singapore–Japan Agreement — Remuneration of a resident of one State for employment exercised in the other State is taxable only in the first State if (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any consecutive twelve-month period, (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and (c) it is not borne by a permanent establishment or fixed base which the employer has in the other State.
Art. 4(2) of the Singapore–Japan Agreement — Dual-resident individual: (a) deemed to be a resident of the State with which his personal and economic relations are closest (centre of vital interests); (b) if that State cannot be determined, of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither, of the State of which he is a national; (d) if he is a national of both States or of neither, the competent authorities settle the question by mutual agreement. There is no permanent-home step; the MLI did not change Art. 4.
ITA 1947, s. 2(1) («resident in Singapore»), 62(4)–(5), 73(1); IRAS — «Working out my tax residency» (updated 12 May 2026) — Status is set for the whole calendar year and applies to the following Year of Assessment. A foreigner arriving is resident for that year with 183 days of presence or employment, or under the two-year or three-year administrative rules; a holder of a work pass valid for at least one year is provisionally treated as resident, and the status is reviewed at tax clearance. A person chargeable to tax notifies IRAS within one month of arrival.
Income Tax Act (Japan), art. 95; NTA Tax Answer No. 1240 — A resident who pays foreign income tax deducts it from Japanese income tax up to the credit limit (income tax for the year × adjusted foreign income ÷ total income); the excess is credited up to the limit for special reconstruction income tax. Unused limits and excess credits carry forward for 3 years. For non-permanent residents only foreign income paid in or remitted to Japan counts. Tax above the treaty rate is not creditable. A statement of foreign tax credit and documents proving the foreign tax are attached to the return.
Art. 23 of the Singapore–Japan Agreement — Japan (Art. 23(1)): credit for Singapore tax against Japanese tax. Singapore (Art. 23(2)): credit for Japanese tax against Singapore tax. The tax-sparing rules of the 1994 Protocol ceased for taxable years after 31 December 2000.
Art. 22(1) of the Singapore–Japan Agreement — Limitation of relief (remittance basis): where income from Japan is relieved from Japanese tax under the Agreement and Singapore taxes it by reference to the amount remitted to or received in Singapore, the relief applies only to the amount remitted or received.
s. 10(1) ITA 1947 — Income tax is payable on the income of any person accruing in or derived from Singapore or received in Singapore from outside Singapore — including gains or profits from any trade, business, profession or vocation, from any employment, dividends, interest, rents, royalties and pensions.
s. 13(7A) ITA 1947 — Exempt is income from sources outside Singapore received in Singapore: (a) by a non-resident individual; (b) from 1 January 2004 — by a resident individual, where the Comptroller is satisfied that the exemption is beneficial to him or her; the exemption does not cover such income received through a partnership in Singapore.
IRAS — «Claiming foreign tax credit» — Where foreign income is taxable in Singapore and foreign tax has been paid on it, a resident can claim a foreign tax credit in the return; the credit is the lower of the foreign tax paid and the Singapore tax payable on that income.
Income Tax Act (Japan), arts 161, 212, 213; NTA Tax Answer No. 2884 — Payers of Japan-source income to non-residents withhold tax: 20.42% on salary and other remuneration for personal services, retirement allowances, real estate rent, loan interest and royalties; 15.315% on dividends and interest on listed shares. Treaty reduction or exemption is claimed by filing the «Application Form for Income Tax Convention» through the payer by the day before payment.
Ministry of Internal Affairs and Communications — Individual inhabitant tax — Individual inhabitant tax is levied on persons with a domicile in a municipality (prefecture) on 1 January of the year. The income levy is 10% (4% prefectural, 6% municipal) of the previous year's income (1 January – 31 December); the per-capita levy is a fixed amount. Employees' tax is normally deducted from salary.
Income Tax Act (Japan), art. 60-2; NTA Tax Answer No. 1478 — A resident who on departure holds securities etc. worth ¥100 million or more and had a domicile or residence in Japan for more than 5 years in total within the 10 years before departure is taxed on the unrealised gains (exit tax). Payment can be deferred for 5 years (extendable to 10) by appointing a tax agent and providing security; the tax can be cancelled on return within that period (claim within 4 months of return).
IRAS — gains from the sale of property, shares and financial instruments (updated 27 February 2026); dividends (updated 27 February 2026) — Gains from selling property and shares are generally not taxed as capital gains unless the sale amounts to trading (frequent transactions, a profit-seeking motive). Dividends of Singapore companies under the one-tier system are not taxed; foreign dividends received in Singapore by a resident are generally not taxed either (except those received through a partnership in Singapore).
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 base income tax is also payable. The special defence income tax of the 2026 reform applies from 2027 (total rate unchanged).
Income Tax Act (Japan), arts 120–121; NTA Tax Answer No. 1900 — Most employees' tax is settled by the year-end adjustment and no final return is needed; a final return is required, for example, for annual salary over ¥20 million, other income over ¥200,000, or salary from a payer with no Japanese withholding obligation.
Act on Submission of Statement of Overseas Wire Transfers, 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 files a statement of foreign assets with the tax office by 30 June of the following year; failure increases penalty tax and can be punished.
Art. 4(2)(a) of the Singapore–Japan Agreement — A dual-resident individual is deemed to be a resident of the State with which his personal and economic relations are closest (centre of vital interests). The Agreement has no permanent-home test.
Art. 4(2)(b) of the Singapore–Japan Agreement — If the State in which he has his centre of vital interests cannot be determined, he is deemed to be a resident of the State in which he has an habitual abode.
Art. 4(2)(c), (d) of the Singapore–Japan Agreement — If he has an habitual abode in both States or in neither, he is deemed to be a resident of the State of which he is a national (c); if he is a national of both States or of neither, the competent authorities settle the question by mutual agreement (d).

Case law

Supreme Court of Japan, Second Petty Bench, 平成20年(行ヒ)第139号, 18/02/2011 — A gift-tax case on «domicile» (former Inheritance Tax Act art. 1-2(1)). A person posted to Hong Kong who spent about two thirds of the posting period there was held not to have a domicile in Japan when the gift was received, even though he spent about a quarter of the period in Japan, worked in Japan as well and adjusted his days in Japan to avoid tax. A tax-avoidance purpose alone does not place a domicile in Japan.

Updated 10/11/2026. The result is for information only and is not tax or legal advice. IRAS, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law can change with each annual Budget. Consult a qualified adviser before making decisions.

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