Technical article

Japan, Korea and Thailand: Death Tax That Reaches Heirs Who Live Elsewhere

The couple wonders whether any of these three countries would tax what they leave, when the parents have never lived in Asia.

By Neil Solomon · 4 min read

Imagine a retired couple in Florida whose daughter lives in Seoul and whose grandson studies in Tokyo. A cousin owns a condo in Bangkok. The couple wonders whether any of these three countries would tax what they leave, when the parents have never lived in Asia. Each country asks a different question, so the answers differ.

The short answer for each

Japan

Japan gives a basic exemption of JPY 30 million (about US$200,000) plus JPY 6 million (about US$40,000) for each statutory heir. Japan works out the tax on statutory shares, then splits it among the people who receive.

The reach is the part that matters for a family abroad. A foreign asset is taxed only when someone in the chain has had a Japanese home in the last 10 years. Temporary visa holders who lived in Japan under 10 of the last 15 years sit outside that rule. An heir who is a Japanese citizen, with no Japanese home in the prior 10 years, is outside the tax if the person who died was a foreigner. Gifts made within 7 years before death are added back. The source is PwC (tier B).

For the grandson in Tokyo, the first question is whether anyone in the chain had a home in Japan in the last 10 years.

Korea

Korea taxes the heir or the person given a gift. A non-resident foreign heir receives a basic deduction of 200 million Korean won (about US$145,000) and nothing else. Korea adds a 30% surcharge when an inheritance skips a generation, say a grandchild receiving directly. The surcharge is 40% when a minor receives more than 2 billion won (about US$1.4 million). Gifts to heirs within 10 years before death are added back, and gifts to non-heirs within 5 years.

The Korean figures come from a Korean tax guide and an advisory firm (tier U). The IRS lists no estate and gift tax treaty with Korea.

For the daughter in Seoul, the question is whether she is a resident. A resident heir is taxed on everything she receives, wherever it sits.

Thailand

Thailand's inheritance tax has been in force since 2016. PwC (tier B) gives 10% on amounts above THB 100 million (about US$3 million) per person who died, and 5% where the heir is a parent or a descendant. A spouse is exempt. A law-firm article from late 2022 (tier C) says a foreign heir who is not domiciled in Thailand pays only on property situated, registered, withdrawn or claimed in Thailand.

Two other sources differ on the threshold for people who are not descendants. A newspaper report from 2015 puts it near THB 10 million. A law-firm guide from 2026 puts it at THB 50 million. For descendants both agree on THB 100 million. Gifts are taxed separately, at 5% above THB 20 million a year when the giver is a parent, a descendant or a spouse.

For the relative with the condo, the property sits in Thailand. The question is the value against the threshold, and who is receiving it.

Who it touches

Children, grandchildren, and a spouse who is a foreign national all meet different columns. A trust may add a layer, which other articles here cover.

Has anyone in your family inherited from, or through, one of these three countries? What did the tax office ask first? Share it here, because someone planning the same move may find your answer useful.

Figures are estimates for planning, based on public data. Date read: October 2026.