edit : title is a mistake, you may or may not have to report depending on your status, please see 'who needs to file' section below.
(With the very weak yen, there are likely more people in scope for this mandatory filing, and there was no wiki page yet, so here you go. This is a draft of a wiki page, after community inputs this will go onto the wiki, your contributions and corrections are appreciated. Examples of fillings would be much appreciated).
Outline
The RFA ('Report of Foreign Assets' as ) is an obligation to declare assets located outside of Japan for tax residents (other than non-permanent tax residents), if they have a value of 50 million yen or more, as of December 31st of the previous year (so 2023 in our case).
Deadline to file is the last day of June (if this is a weekend, then the following Monday). So for 2023, the deadline is Monday 1st of July 2024.
Not the only reporting requirement: 'Report of Assets and Liabilities'
Be aware there is also an additional requirement to declare worldwide assets and liabilities for larger amounts, but it is not discussed in this page. It is mentioned here by the NTA.
Individual taxpayers with income tax return filing requirement and whose net income in the year exceeds JPY 20 million
AND
Who hold worldwide assets with a gross fair value of JPY 300 million or more as of December 31st of the previous year
OR
hold assets subject to the exit tax amounting to JPY 100 million or more as of December 31st of the previous year.
Reference documents
The NTA english explanation for 2023, see the 'Report of Foreign Assets' section.
The NTA page detailing the obligation No 7456 (jp)
The NTA page indicating how to file and links to the PDF forms for paper/mail submissions (jp) including the guide on what to write down (jp).
Presentation documents in English from PWC (2015) and KPMG (2013) Beware that those have outdated information such as the filling deadline of March in the 2015 PDF (it is now end of June).
Who needs to file
Tax residents (other than non-permanent tax residents) whose overseas assets have a gross fair value of JPY 50 million or more on December 31st of the previous year (regardless of whether the individual is required to file a tax return).
Tax and cost
The obligation to file does not generate specific tax or submission costs.
Penalties for failure to file
Please note that if the relevant foreign country exchange financial data with Japan, the NTA likely already have access to your foreign financial accounts. This is part of automated exchange under the CRS program. CRS does not include other type of assets (material, real estate) that are in scope of OAR.
In addition, penalties for failure are :
According to the statute:
正当な理由がなくて国外財産調書をその提出期限までに税務署長に提出しなかったときは、その違反行為をした者は、一年以下の懲役又は五十万円以下の罰金に処する。ただし、情状により、その刑を免除することができる.
In other words, the penalty for not filing "without good justification" is up to one year imprisonment or a fine of up to 500,000 yen. However, the statute explicitly allows for the penalty to be waived. In practice, I expect penalties are very unlikely to be imposed in cases where the taxpayer clearly wasn't aware of their obligation or just forgot to file it, etc. Penalties are most likely reserved for cases where (1) the taxpayer clearly had the intention to evade tax by hiding assets and/or (2) the NTA repeatedly asked the taxpayer to file the report and the taxpayer repeatedly refused to file it. (comment source)
Valuation
Values must be declared as of December 31st of the previous year. Market values at that date should be used.
Submission
You can use the e-tax desktop software, use commercial software, or simply fill one of the PDF on the NTA page and drop or mail the paper to your tax office.
How to file – examples
The NTA guide linked above describe how to fill each cell, in Japanese only.
Reporting is due in JPY, using the rate as of December 31st. One should use the rate published by the institution they use for their regular banking, but this MUFG site is very popular as an archive of exchange rates.
Name, address, MyNumber, phone number, and total amount must be indicated.
As per the NTA guide, there are different information needed depending on the nature of the asset being reported, so reading the guide carefully for each relevant asset category is important. The guide examples are also helpful.
by Junin-Toiro
4 comments
A few examples taken from the guide as I understand it (not proper financial advice), as you can see different assets need different info :
* A private bank account with cash would be category 預貯金 type 普通預金 purpose 一般用 (not business).
* An investment accounts with equities would be category 有価証券 type 上場株式 and value shown in the higher cell (上段は有価証券等の取得価額) the acquisition value (at dec 31st exchange rate), while the lower cell (価 額) the market value (on dec 31st and at the exchange rate of that day). Number of shares must also be indicated.
* Precious metal like gold would be 貴金属類 type 金, and the quantity (ek 1g) indicated.
Thank you for the post and the reminder. I have a question about other people’s experience with this. I had to submit this year and I found it to be kind of a hassle to fill out the documents. I was told that I had to list every stock seperately, so finding the purchase price and then using the date of purchase to find the yen value on that date of purchase (usually several years ago) for each stock to a lot of work with excel. It was more complicated when there were stocks that I had bought and sold several times. Am I being too careful with this? Is everyone else doing the same thing?
I had no idea this was a thing. It should be in the wiki
If they have access and know how much you have. Can’t they tell you how much you should pay
This is interesting, but realistically speaking, I don’t know about everyone else, but it’s simply not possible to accurately know all of these things at all times, and I’m wondering what everyone is doing about this general concept of “learning random things from random posts inconsistently and realizing you may have been non-compliant already.” Pretty much everyone I know whom I discuss this with in person just pleads ignorance, and I’ve never met anyone who has ever been contacted, much less penalized.
I’m of the mind though, that ignorance is not good, but at the same time, expectation of perfection is also not realistic.
People have said, “consult an accountant,” but I have not been able to find an accountant that will: a) handle small fish AND b) consult on foreign matters like foreign assets. I talked to someone once about the global taxation thing on things like dividends after X amount of years, and just got blank stares.
I’m actually scheduled with the local city hall tax office on Monday for a 30 minute free consultation. My approach is now, I’m going to go in there with all of my info and suspicions, and ask them to tell me what flags they see and what they suggest.