Based on the experience of various countries, taxpayers of real estate tax can be owners, usufructuary holders, and actual users (occupants or tenants). Since each country has real estate registration systems, it is common practice to designate the real estate owner listed in the real estate registry as the taxpayer of real estate tax. From the functional perspective of real estate tax, not only the owner but also the usufructuary owner and actual user can all be taxpayers. Based on the priority order determined by taxpayers, the practices of various countries and regions can be divided into the following three types (see Figure 4).

# (2) Taxable Objects (i.e., physical real estate)
The taxable objects of real estate tax should cover all types of real estate as much as possible, especially those for private use and profitable properties, thereby achieving adequacy and fairness in tax collection. In addition, the determination of taxable objects for real estate tax is also related to the availability of relevant data and is linked to the overall tax system of a country. From international experience, the objects of real estate tax are land and permanent improvements on land, including buildings and structures; A few countries tax only land or only houses (see Figure 5).

The tax base for real estate tax can be divided into two main models: ad valorem taxation and specific quantity taxation. Among them, specific taxation (such as by building area) is relatively simple to operate but less fair. The ad valorem model increases the complexity of base assessment but offers higher fairness. Looking at the development of the real estate tax system, with the continuous advancement of tax base assessment technology, the tax base has shifted from quantity to price. Currently, most countries worldwide adopt an ad valorem taxation model. A few less developed countries still retain the specific taxation method. Israel is the only developed country to use specific taxation. Although it has improved the area-based taxation method and incorporated factors such as location corrections, there is still a serious problem of tax base inequality.
For countries adopting the ad valorem tax model, the tax base for real estate tax can be further divided into three types: taxation based on asset value, taxation based on annual rental value, and taxation based on registered value (see Figure 6).

Asset value. Asset value is the transaction value that can be realized under open market conditions at the time of appraisal, including the property's use value and expected future appreciation. Using asset value for tax purposes not only achieves the return of land value to the public but also strengthens the progressive taxable value, enabling wealth redistribution. Tax base based on asset value is required to be updated regularly to more accurately reflect market value. In countries with mature real estate taxes, asset value is mostly used as the tax base.
Annual rental value. Annual rental value is the annual rent a property can receive under open market conditions, assuming an indefinite lease. Annual rental value mainly reflects the use value of the real estate and does not include expectations of future appreciation. Using rental value for taxation requires certain levels of activity in the real estate market. The more active the real estate market is and the more data used to determine rent, the more accurate the annual rent assessment value will be. Countries and regions that use rental value as the tax base are mainly those heavily influenced by the UK, such as India, Singapore, and Hong Kong. The UK once used annual rental value, but after several reforms, it now adopts an asset-based taxation method
Registered value (cadastral value). Taxed at registered value is mainly in continental European countries. The registered value is mainly used for tax purposes, with specialized valuation methods, usually lower than the asset value and market transaction price. In countries that adopt this model, laws usually require regular updates to registered values, but in practice, many countries do not strictly follow the law for regular updates. For example, in European countries such as Germany, Italy, and Spain, there are issues such as the tax base not being updated for a long time, or updating it only through simple price index adjustments. As a result, the tax base differs greatly from the market level, failing to reflect market changes, which not only reduces tax revenue but also undermines tax fairness. Successful cases of updating the tax base include Japan and South Korea. Japan updates its registered value every three years, while South Korea updates it annually.
The "expenditure-based revenue" tax rate divides the amount of public fiscal expenditure supported by local governments' property tax for the following year by the tax base size of the current year's real estate tax, thereby obtaining the property tax rate for the following year. The advantage of this approach is linking fiscal revenue decisions with expenditure decisions, thereby helping to improve public fiscal efficiency. The "expenditure-based revenue" approach requires regular updates of taxable value. Typical countries with pay-as-based income include the United States, United Kingdom, Canada, France, and South Africa.
Fixed tax rate. In countries and regions with a high degree of fiscal centralization, real estate tax rates are often fixed by law; typical countries and regions include South Korea, Singapore, and others. In some countries, such as Germany and Japan, the central government empowers local governments to fine-tune tax rates based on the same standard tax rate, reflecting differences in public service needs between regions. Among them, German local governments adjust tax rates by adding a "multiplier" to the tax rate, while Japan directly adjusts the rate up or down based on the standard rate set by the central government.
In addition, real estate tax rates in various countries can be divided into three types: single rates, classified rates, and progressive rates. A single tax rate applies uniformly to all real estate properties, typical countries and regions such as Japan and the Hong Kong Special Administrative Region of China. Classified tax rates apply different rates to different types of real estate. A common practice is to classify real estate by use and set different tax rates. Generally speaking, commercial and industrial tax rates are higher, while residential tax rates are lower. For example, parts of the United States, Canada, and Germany. Some countries also set different tax rates on land and buildings, such as South Korea. Singapore's property tax applies progressive rates to residential properties based on the residential and commercial classification rates.
# (5) Tax reductions and tax burden restriction measures
The reasons countries implement real estate tax reductions or restrictions usually include: reducing the tax burden on low-income or specific groups to ensure their basic standard of living; Reducing the tax burden on certain types of real estate (such as residential) to support such uses, such as ensuring basic housing needs; Attracting foreign investment by reducing tax burdens in specific regions; Local governments also often win taxpayer support by introducing tax relief measures.
Tax reductions can be divided into four categories based on the tax base, tax rate, tax amount, and deferred tax payment (see table below). In terms of scope and effect, the scope and effect of tax base reductions are broad, but their targeting is poor, making it easier to cause tax base loss and unfair tax burden distribution. In contrast, tax rate reductions and tax amount reductions linked to taxpayer income are more targeted and relatively fairer.

# (6) Taxable value assessment
Real estate taxable value appraisal is a type I real estate valuation used for tax purposes. The taxable value assessment of real estate tax not only needs to accurately reflect the market value of the appraised object at the time of appraisal, but more importantly, it is important to ensure that the price relationships between the appraised objects accurately reflect market conditions, thereby achieving fair allocation of the tax burden. Compared to real estate market value assessments serving other purposes such as real estate transactions, taxable real estate value assessments place greater emphasis on fairness and explainability of the results.
Moreover, taxable value assessment for real estate focuses more on the value brought by the public services currently enjoyed, reflecting the benefits of the property tax, while less considering the impact of future changes in real estate returns on the present value of real estate. For example, in many countries, the taxable value assessment of real estate does not take into account the remaining useful life of the property.
Real estate tax assessment requires evaluating a large number of properties within a short period and producing relatively fair and consistent evaluation results. With the application of batch assessment models and the development of computer-aided batch assessment systems, the efficiency and accuracy of taxable value assessment for real estate tax have greatly improved.
# (7) Evaluation AgenciesThe establishment of real estate tax appraisal departments usually follows the principle of "evaluation and tax administration standing apart," ensuring fairness and objectivity in appraisal. From the perspective of the hierarchy of appraisal departments, property tax assessments are mostly handled by municipal governments, while some countries and regions are managed by state/provincial governments. There are fewer countries where central or federal tax authorities are responsible for property tax administration, and even fewer countries have actual appraisal functions.
From the perspective of government departments under the property tax appraisal department, they can be roughly divided into five categories. The first category is those affiliated with the finance or tax authorities. Typical cases include the United Kingdom, Singapore, and the Hong Kong Special Administrative Region of China. Additionally, in countries like France and Italy, the taxable value of real estate tax is managed by local government tax authorities, without dedicated appraisal departments. The second category is the establishment of an independent property tax assessment department. A typical case is the provinces of British Columbia and Ontario, Canada, which established assessment departments directly under provincial governments through the form of "statutory bodies." The third category is those under municipal or county governments, with the United States as a typical case. The fourth category is assessed by the land department or real estate registration department. Typical cases include Australia, Lithuania, and South Korea. The fifth category is when municipal and county governments conduct real estate tax assessments by appointing appraisers. Typical cases include Japan and South Africa.
In real estate tax administration, taxpayers may raise objections to the assessment results, relevant policies applied in determining the tax amount, and other relevant content. Therefore, many countries have established dispute resolution mechanisms for property taxes.
In countries with more mature property taxes, dispute resolution mechanisms are usually divided into three levels. The first layer is to submit an "informal" dispute resolution application to the property tax appraisal agency. Typically, taxpayers submit applications to appraisal agencies through consultation, which will provide explanations to the taxpayers. From the perspective of national practice, most disputes can be resolved at this level. The second level is to submit a "formal" dispute resolution application to the agency responsible for handling real estate tax disputes. Such disputes require specialized dispute resolution teams. In countries like the United States and Canada, complaints are usually handled through hearings, with taxpayers and appraisal agencies presenting evidence separately. The third level is filing a lawsuit with the court. Generally, lawsuits filed in court are related to specific legal provisions and must not target data, formulas, etc. in the appraisal.
Besides dispute resolution systems, "appeals must not affect tax payments" is also a common practice in many countries. After review, if it is indeed necessary to change the assessed value and tax amount, the tax authority will refund or make up the corresponding tax to the taxpayer after the dispute is resolved.
Real estate tax is usually levied annually. However, some countries and regions have introduced installment payments to ease the pressure on taxpayers' cash flow from one-time payments, such as twice a year (semi-annually), quarterly four times a year, or monthly. To facilitate taxpayers, various countries offer various payment methods, including over-the-counter payments, bank transfers, and online payments. In the United States, taxpayers in the mortgage repayment period can open a dedicated bank account to pay property taxes on behalf of the bank.
The property tax appraisal department will issue the assessment results to the taxpayer in the form of an appraisal notice. In addition to informing the appraisal results, the appraisal notice also provides some real estate-related information used for the appraisal, making it easier for taxpayers to understand the appraisal results. Additionally, the appraisal notice will specify the dispute handling process and timeline, as well as the method for publicly querying appraisal results. On the surface, transparency in tax assessment information helps increase taxpayers' support for property taxes and helps reduce disputes.
The disclosure of real estate tax assessment results is a common trend in the fields of real estate tax collection and administration across countries. On one hand, this makes the entire appraisal process more transparent and easier for taxpayers to supervise; on the other hand, by comparing the appraisal results between their own and neighboring houses, taxpayers can assess the accuracy of the appraisal results, helping to reduce disputes. Some local governments provide year-round inquiries about the assessment results on dedicated websites. To protect privacy, websites often only publish real estate addresses and appraisal results, allowing taxpayers to view detailed information about their properties after logging in. The advantage of this approach is that the assessed value of real estate tax, as a type of government public information, serves as an important price reference in real estate market transactions, facilitating smooth market transactions. Therefore, the publicly available valuation value inquiry platform also serves as a public information release function.
In addition to the appraisal notice issued by the appraisal department, the tax authority also issues tax payment notices to taxpayers. The tax notice will indicate the applicable assessed value, tax rate, and reduction policies. The more detailed the content, the easier it is for taxpayers to understand the tax calculation process and reduce disputes caused by unclear tax calculation methods. In addition, the tax notice will detail the time of payment, the channels, and the dispute handling process. With the widespread adoption of internet technology, tax authorities are issuing paper tax bills while increasingly adopting electronic tax invoices.
# (10) Disposal and compulsory enforcement of tax arrears
In countries with relatively well-developed real estate tax systems, for taxpayers who refuse to pay taxes, the government often first imposes late fees and interest on the portion owed. If the tax arrears are still not paid, mandatory penalties such as freezing or auctioning property are implemented to create a strong deterrent effect. The enforcement system applies to a very small number of taxpayers who owe taxes. For the vast majority of taxpayers, countries mainly encourage compliance by providing better tax services and more transparent information disclosure systems. In practice, the enforcement intensity adopted by different countries (regions) also varies greatly.
Taking the process of handling property tax arrears in Michigan, USA, as an example, the disposal of arrears can generally be divided into three stages (see Figure 7). The first stage is to collect interest and late fees on the unpaid portion of the tax; the second stage is to establish a "Tax Lien" on the tax-owed real estate; the third stage is to cancel the redemption right (foreclosure) of the tax-owed real estate, auction it off by the government, and the proceeds are prioritized for repaying the arrears.
