Buying an entire rental apartment building to shrink an inheritance tax bill is a technique that owners in Japan have relied on for decades. Japan's FY2026 tax reform (令和8年度税制改正) now revisits it. The short version: within the FY2026 reform announced in 2026, the change that matters most to real estate investors is the "revised inheritance tax valuation of leased real estate" that takes effect from January 2027 (令和9年1月) — widely called the "five-year rule." Alongside it, the electronic-filing requirement for the blue-return special deduction, the increase of the low-value depreciable-asset threshold to under 400,000 yen (approx. USD 2,700), and the five-year extension of the mortgage tax credit all bear on how you acquire, hold, file for, and pass on a property. Drawing on primary sources from Japan's Ministry of Finance (財務省, MOF) and Ministry of Land, Infrastructure, Transport and Tourism (国土交通省, MLIT), this article maps where each change actually hits an investment decision. For overseas investors, note upfront that several of these mechanisms — the "blue return," the government valuation directive, the five-building/ten-room test — have no direct equivalent in US or UK tax law, so we explain each one as we go.
Key points of this article
- The FY2026 tax reform change with the greatest impact on real estate investment is the revised inheritance tax valuation of leased real estate (the five-year rule), which applies from January 2027 (令和9年1月).
- Leased real estate acquired or newly built within five years before the inheritance begins is, in principle, expected to be valued at its ordinary transaction price.
- The blue-return special deduction splits into 750,000 yen (approx. USD 5,000), 650,000 yen (approx. USD 4,300), and 100,000 yen (approx. USD 670) depending on electronic filing and electronic bookkeeping, applying from the 2027 (令和9年) tax year.
- The mortgage tax credit is extended five years, through move-ins by the end of 2030 (令和12年末), and the special rule for low-value depreciable assets is raised to under 400,000 yen (approx. USD 2,700).
Where does the FY2026 tax reform actually affect real estate investment?
The outline (大綱, taikō — the ruling coalition's annual tax reform blueprint) for the FY2026 tax reform was approved by the Cabinet on December 26, 2025 (令和7年12月26日). Built around responding to high prices and lifting the wider economy, it bundles measures such as raising the basic deduction and lifting the minimum guaranteed employment-income deduction from 650,000 yen (approx. USD 4,300) to 690,000 yen (approx. USD 4,600). That said, only a subset of these changes bears directly on a real estate investment decision.
What an investor should hold onto is the discipline of separating impact by stage: acquisition, holding, sale, and succession. This time in particular, the changes that reset the ground rules of inheritance and succession sit at the center. First, here is the whole picture at a glance. Unlike the US or UK, where estate-planning tax rules and income-tax filing rules are administered by a single federal authority (the IRS, HMRC), several of these items are set by the National Tax Agency (国税庁, NTA) through administrative directives rather than by primary statute — which is why some figures below remain provisional.
| Reform item | Main content | Timing |
|---|---|---|
| Revised inheritance tax valuation of leased real estate (five-year rule) | Certain leased real estate acquired or newly built within five years before the inheritance begins is valued at its ordinary transaction price, not under the Property Valuation Basic Directive (財産評価基本通達, zaisan hyōka kihon tsūtatsu) | Inheritances and gifts on or after January 1, 2027 (令和9年1月1日) |
| Revision of the blue-return special deduction | 650,000 yen (approx. USD 4,300) with electronic filing; 750,000 yen (approx. USD 5,000) if electronic bookkeeping is also met; 100,000 yen (approx. USD 670) for paper filing | From income tax for the 2027 (令和9年) tax year |
| Special rule for low-value depreciable assets | Threshold raised from under 300,000 yen (approx. USD 2,000) to under 400,000 yen (approx. USD 2,700); application period extended three years (for small and medium-sized enterprises and similar taxpayers) | Extended per the outline |
| Mortgage tax credit | Application period extended five years. Higher borrowing ceilings for energy-efficient existing homes, credit period expanded to 13 years, floor-area requirement eased | Move-ins from January 1, 2026 (令和8年1月1日) through December 31, 2030 (令和12年12月31日) |
| Property tax reduction for newly built homes | Application period extended five years, floor-area requirement changed to 40–240 m² (approx. 430–2,580 sq ft), and location requirement for disaster-hazard areas revised | April 1, 2026 (令和8年4月1日) through March 31, 2031 (令和13年3月31日) |
| Real estate acquisition tax special measure | Scope of the special measure expanded and application period extended two years, with the floor-area requirement eased to 40 m² (approx. 430 sq ft) or more | Extended per the outline |
The precise statutory positioning can be confirmed in the summary of the FY2026 tax reform outline published by the Ministry of Finance (財務省, MOF). Below, we work through the details in order of how much they matter to investors.
What is the revised inheritance tax valuation of leased real estate (the five-year rule)?
The change in this reform that hits real estate investment hardest is the revised inheritance tax valuation of leased real estate. In a sentence: it moves the assessed value of a rental property bought just before an inheritance closer to its market value. It is set to apply to inheritances and gifts on or after January 1, 2027 (令和9年1月1日).
Until now, a widely used technique has been to acquire a rental apartment with borrowed funds and use the gap between market value and inheritance tax assessed value (the valuation gap) to shrink the total taxable estate. This valuation gap is a distinctly Japanese feature: inheritance tax value is normally set under the Property Valuation Basic Directive (財産評価基本通達), an NTA administrative rule that routinely values property well below its market price — unlike the US federal estate tax or the UK, where property is generally brought into the estate at fair market value, leaving little comparable gap to exploit. After the reform, for certain leased real estate that the decedent (or a similar person) acquired or newly built through a transaction for consideration within five years before the taxable date, valuation will use the ordinary transaction price rather than the Property Valuation Basic Directive. The starting point for understanding it is simple: buying at the last minute, right before an inheritance, will no longer deliver much of the compression effect.
The outline states that where no tax abuse is found, valuation may use an amount equal to 80% of a figure calculated from the acquisition price with adjustments for land-price movements and the like. However, this is a policy set at the outline stage, and the specific treatment will be defined by a future revision of the Property Valuation Basic Directive. The finer points of the figures and scope need to be confirmed once the NTA directive is issued.
The other key point is the holding period. The target is strictly property acquired or newly built "within five years"; it does not immediately change the valuation of real estate that has been held for a long time. The use of real estate for inheritance planning has not itself been rejected — rather, the reform means investors now need to weigh the time axis from purchase to inheritance more deliberately than before. If you are considering a stocktake of holdings with inheritance in view, please also see our discussion of how to think about inheritance tax measures in apartment management.
The revised blue-return special deduction and the practicalities of depreciation
The first thing to check on the filing side while you hold a property is the revised blue-return special deduction. The bottom line: if you file electronically you keep the 650,000 yen (approx. USD 4,300), but if you file on paper it drops to 100,000 yen (approx. USD 670). It applies from income tax for the 2027 (令和9年) tax year, and from FY2028 (令和10年度) for individual resident tax. The blue return (青色申告, aoiro shinkoku) is itself a uniquely Japanese arrangement: taxpayers who keep certified double-entry books in exchange for deductions and other benefits — there is no exact counterpart in the US Schedule E or the UK self-assessment system, where no comparable bookkeeping-linked deduction exists.
The revised tiers are as follows. Keep books under proper double-entry bookkeeping principles and file via e-Tax within the deadline, and the deduction is 650,000 yen (approx. USD 4,300). Meet the additional requirement of storing your journals and general ledgers electronically, and it becomes 750,000 yen (approx. USD 5,000). File on paper, on the other hand, and it stays at 100,000 yen (approx. USD 670). For blue-return owners whose real estate income reaches business scale (jigyō-teki kibo, 事業的規模 — the common rule of thumb is five buildings or ten rooms), moving to electronic filing becomes, in practice, hard to avoid. Preparing accounting software and electronic bookkeeping during 2026 (令和8年) is the safe course.
On the acquisition side, the special rule for low-value depreciable assets (少額減価償却資産, shōgaku genka shōkyaku shisan) also changes. The threshold on acquisition price is raised from under 300,000 yen (approx. USD 2,000) to under 400,000 yen (approx. USD 2,700), and the application period is extended three years (for small and medium-sized enterprises and similar taxpayers). This makes it easier to expense in the year of acquisition equipment such as air conditioners and water heaters that previously edged just over the threshold. Compared with the US de minimis safe harbor or Section 179 expensing, Japan's version is tied to this specific yen threshold and its periodic extensions, so the timing of the outline's renewal matters. Depreciation is a factor that shapes cash flow and tax burden during the holding period. We lay out the fundamentals in how to think about depreciation expense in real estate investment. If you are weighing the timing or scale of equipment renewal, you can review it together with the income and expenses of your holdings in a free consultation with INA.
Extensions and eased requirements for the mortgage tax credit, real estate acquisition tax, and property tax
Most of the special measures tied to acquisition costs were extended and expanded. Note, however, that each of these centers on owner-occupied homes or newly built homes, and does not apply as-is to rental investment properties.
The mortgage tax credit has its application period extended five years, covering move-ins from January 1, 2026 (令和8年1月1日) through December 31, 2030 (令和12年12月31日). For existing homes with high energy performance, the borrowing ceiling is raised, the credit period is expanded to 13 years, and additional measures are provided for child-rearing households and young married households. The floor-area requirement is eased to 40 m² (approx. 430 sq ft) or more, and this applies to existing homes as well (those with total income over 10,000,000 yen (approx. USD 67,000) and users of the additional measures need 50 m² (approx. 540 sq ft) or more). The details are published in the press release from the Ministry of Land, Infrastructure, Transport and Tourism (国土交通省, MLIT).
The property tax reduction for newly built homes is extended five years, from April 1, 2026 (令和8年4月1日) through March 31, 2031 (令和13年3月31日), and the floor-area requirement changes to 40 m² or more and 240 m² or less (approx. 430–2,580 sq ft; previously 50 m² or more and 280 m² or less). The location requirement for disaster-hazard areas is also revised. For the real estate acquisition tax, the scope of the special measure is expanded, the application period is extended two years, and the floor-area requirement is eased to 40 m² (approx. 430 sq ft) or more. The reduction for the registration and license tax on residential buildings is also extended. The overall picture of tax burdens during the holding period is easier to organize when read together with the basics of property tax on real estate.
From an investor's standpoint, the practical way to read these extensions is as support for owner-occupier buyers and genuine end-user demand. They are a factor that underpins the base of rental demand, but they do not directly lower the acquisition cost of an investment property.
The decisions real estate investors should make under the FY2026 tax reform
Once you grasp the whole picture of the reform, the next step is to judge where it hits from your own position. We have organized the changes worth watching and the actions worth considering, by investor type.
| Investor type | Changes that mainly apply | Actions to consider |
|---|---|---|
| Owners with inheritance and succession in view | Revised inheritance tax valuation of leased real estate (five-year rule) | Recheck the time axis from acquisition to inheritance. Rather than relying on last-minute buying, revise the succession plan to include the holding period |
| Business-scale owners holding multiple properties | Revised blue-return special deduction, special rule for low-value depreciable assets | Move to electronic filing and electronic bookkeeping during 2026 (令和8年). Plan equipment renewal with the under-400,000-yen (approx. USD 2,700) lump-sum expensing in mind |
| Owners considering a sale (exit) | Revised inheritance tax valuation, the framework of transfer taxation | Compare continued holding as an inheritance measure against selling, on an after-tax net basis. Weigh the timing of the exit in numbers |
| Investors about to acquire | Low-value depreciable assets, acquisition-cost-related special measures | Design the post-acquisition filing setup in advance. For an owner-occupied purchase, confirm the eligibility requirements for the mortgage tax credit |
Those thinking about succession in particular should note that the gift tax exemption for lump-sum gifts of educational funds will not be extended beyond its application deadline of March 31, 2026 (令和8年3月31日). Separating the measures you can still use from those reaching their deadline is the first step in designing a succession plan. If you are torn between selling and continuing to hold, please also refer to how to think about real estate exit strategy, sale timing, and taxes.
At INA&Associates Inc., we treat tax reform not as mere tax-saving information but as a set of issues tied to real estate management decisions. It means looking beyond short-term tax savings to succession and exit five and ten years out — and telling you honestly not only about the benefits but also about the premises and constraints. We believe long-term trust is built from that accumulation. When you are unsure how to translate the meaning of the numbers into practice, please feel free to consult us.
Frequently asked questions (FAQ)
Q1. Which part of the FY2026 tax reform has the biggest impact on real estate investment?
The revised inheritance tax valuation of leased real estate (the five-year rule), which applies from January 2027 (令和9年1月). The valuation of a rental property acquired just before an inheritance moves closer to market value, and the inheritance measures that relied on the valuation gap become less effective. It has become necessary to be more conscious of the time axis from acquisition to inheritance.
Q2. Does the five-year rule also apply to rental property I already own?
The target is certain leased real estate acquired or newly built within five years before the inheritance begins (the taxable date). Property held for more than five years is expected to remain under the conventional valuation as a rule, and transitional measures are expected to be provided for buildings constructed on land already owned as of the date the NTA directive is issued, and similar cases. The finer points will be finalized by a future revision of the Property Valuation Basic Directive.
Q3. Can I still receive the 650,000 yen (approx. USD 4,300) blue-return special deduction?
If you file via e-Tax within the deadline, the 650,000 yen (approx. USD 4,300) is maintained. Meet the electronic bookkeeping requirement for journals and the like and it rises to 750,000 yen (approx. USD 5,000); file on paper and it drops to 100,000 yen (approx. USD 670). It applies from income tax for the 2027 (令和9年) tax year. Business-scale owners would do well to consider moving to electronic filing during 2026 (令和8年).
Q4. Can the mortgage tax credit be used for rental investment properties?
No. The mortgage tax credit is for homes you live in yourself and cannot be used for rental investment properties. This five-year extension also assumes owner-occupied use. As a factor underpinning genuine end-user demand, however, it is still worth grasping when reading the backdrop of rental demand.
Related reading
- Tax-saving strategy using depreciation in sectional (condo) apartment investment
- Real estate business succession and M&A as an option
Citations and references
This article is a general explanation based on published information such as the outline approved by the Cabinet on December 26, 2025 (令和7年12月26日). Individual tax calculations and eligibility depend on the requirements. For actual decisions, please confirm with a professional such as your advising tax accountant.
- Ministry of Finance (財務省, MOF), "Summary of the FY2026 Tax Reform Outline"
- Ministry of Finance (財務省, MOF), "FY2026 Tax Reform Outline" (Cabinet decision, December 26, 2025 / 令和7年12月26日)
- Ministry of Land, Infrastructure, Transport and Tourism (国土交通省, MLIT), "Overview of the FY2026 Tax Reform" (December 2025 / 令和7年12月)
- Ministry of Land, Infrastructure, Transport and Tourism (国土交通省, MLIT), press release, "Extension and Expansion of the Mortgage Tax Credit and Related Measures Approved by the Cabinet"
- National Tax Agency (国税庁, NTA)
