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Contents
Summary 277
9.1 Introduction 277
9.2 Broad international comparisons 278
9.3 Recurrent taxes on immovable property 279
9.4 Recurrent taxes on net wealth 281
9.5 Estate, inheritance and gift taxes 282
9.6 Taxes on fi nancial and capital transactions 284
AppendicesAppendix 9.1: Taxes on immovable property 290Appendix 9.2: Estate, inheritance and gift taxes 293Appendix 9.3: Taxes on the transfer of real estate 296Appendix 9.4: Examples of other fi nancial and capital transaction taxes 297
Page 277
9. PROPERTY AND TRANSACTION TAXATION
SUMMARY
Although Australia has a comparatively high reliance on property and transaction taxes (3.0 per cent of GDP) and is seventh highest of the OECD-30, in terms of the OECD-10, Australia’s overall tax burden is much closer to the unweighted average (2.7 per cent).
Most property and transaction taxes in Australia are levied by sub-national governments — the State, Territory and local governments.
Australia’s tax burden from taxes on immovable property is below the unweighted average of the OECD-10.
Of the OECD-10, Australia has the highest financial and capital transaction tax burden (includes taxes such as stamp duties on conveyances).
Australia’s top rate for stamp duty on conveyances (7 per cent) is the equal second highest of the OECD-10.
Australia is the only OECD-10 country which does not levy either a recurrent wealth tax, or any estate, inheritance or gift taxes.
9.1 INTRODUCTION
Property and transaction taxes cover taxes levied on the use, ownership or transfer of property, including:
• taxes on immovable property, for example, land tax and municipal rates;
• taxes on net wealth;
• taxes on the change of ownership of property through inheritance or gift; and
• taxes on financial and capital transactions, for example, stamp duties on conveyances and cheques.
This chapter compares Australia’s property and transaction tax burden with the other OECD-10 countries over these four sub-categories. Information on the comparison across the OECD-30 is included in Chapter 3.
As for other areas where the OECD data are disaggregated finely, there are classification issues which mean that particular care needs to be taken in making comparisons across countries (and through time).
International comparison of Australia’s taxes
Page 278
A wide variety of taxes fall into the property and transaction taxes category and there is considerable diversity between countries in the implementation and design of these taxes.
In Australia, virtually all taxes covered by this category are levied by the sub-national governments. In the other OECD-10 countries, the levels of government imposing these taxes differ. For the majority, sub-national governments are more reliant on these taxes than national governments as a source of revenue.
9.2 BROAD INTERNATIONAL COMPARISONS
As discussed in Chapter 3, Australia has a comparatively high reliance on property and transaction taxes (3.0 per cent of GDP) and is eighth highest of the OECD-30. In terms of the OECD-10, Australia’s overall tax burden in this category is much closer to the unweighted average. Australia is fourth highest in terms of tax burden of the OECD-10 (see Chart 9.1).
Chart 9.1: Property and transaction tax burden OECD-10, taxation revenue as a proportion of GDP, ordered by tax burden, 2003
0
1
2
3
4
5
NZ
Irela
nd
Net
herla
nds
Sw
itzer
land
Japa
n
Spa
in US
Can
ada
UK
0
1
2
3
4
5
Immovable property Recurrent taxes on net wealth Estate, gift and inheritanceTransactions Other property
Aus
tral
ia
Unweighted average
Per cent of GDP Per cent of GDP
Source: OECD Revenue Statistics, 2005. As is the case for all OECD countries, there is considerable diversity across the OECD-10 in the mix of property and transaction taxes.
As shown in Chart 9.2, the Australian mix is quite different from the average OECD-10 mix. Australia’s proportion of the tax mix from immovable property taxes is below the average, whereas Australia’s transaction tax burden is significantly above the average.
Australia does not have wealth taxes or estate, inheritance and gift taxes. The other OECD-10 countries all levy at least one of these types of taxes. (New Zealand imposes a gift tax, but the revenue collected from this tax is less than 0.01 per cent of GDP.)
Chapter 9: Property and transaction taxation
Page 279
Chart 9.2: Australia’s property and transaction tax mix OECD-10, 2003
Australia OECD-10 average
Property taxes
Transaction taxes
Property taxes
Transaction taxes
Other
Wealth taxes Estate & gift
Source: OECD Revenue Statistics, 2005.
9.3 RECURRENT TAXES ON IMMOVABLE PROPERTY
Recurrent taxes on immovable property are defined by the OECD as taxes levied regularly in respect of the use or ownership of immovable property. Usually, these taxes are levied on land and/or buildings.
In Australia’s case, the majority of revenue under this category is from local government rates. Land taxes levied by State and Territory governments are also a significant component.
Taxes on immovable property do not include taxes on incomes flowing from property ownership (for example, rental income) or taxes on incomes flowing from the sale of property (for example, capital gains). These types of taxes are included in the relevant categories of income taxation revenue.
While Australia has the seventh highest immovable property tax burden (1.4 per cent of GDP) of the OECD-30, it is below the average of the OECD-10 (1.6 per cent).
Of the OECD-10, the United Kingdom has the highest reliance on immovable property taxes, and the United States, Canada, Japan and New Zealand are also relatively heavily reliant.
International comparison of Australia’s taxes
Page 280
Chart 9.3: Taxes on immovable property OECD-10, taxation revenue as a proportion of GDP, ordered by tax burden, 2003
0.0
0.5
1.0
1.5
2.0
2.5
3.0
3.5S
witz
erla
nd
Irela
nd
Spa
in
Net
herla
nds
NZ
Japa
n
Can
ada
US
UK
0.0
0.5
1.0
1.5
2.0
2.5
3.0
3.5
A
Unweighted average
Aus
tral
ia
Per cent of GDP Per cent of GDP
Source: OECD Revenue Statistics, 2005. Among the OECD-10, these types of taxes are generally levied by sub-national governments. As such, analysis of their characteristics is more difficult, because information on rates and bases is not as readily available and can vary widely within countries.
Table 9.1 summarises the number of these types of taxes levied in the OECD-10 and the different levels of government levying them. Table 9.2 summarises the tax bases used in the OECD-10. Comparable information on rates and bases is not readily available and the information in the following tables must be treated with caution as the detailed information has not been verified with the individual countries.
Table 9.1: Number of recurrent taxes on immovable property in the OECD-10 countries National government State government Local government Australia - 1 1
Canada - - 1
Ireland - - 1
Japan - - 3
Netherlands - - 1
New Zealand - - 1
Spain - - 1
Switzerland - 1 -
United Kingdom 1 - 1
United States - 1 1 Source: Various, see Chapter 1 (1.4.1).
Chapter 9: Property and transaction taxation
Page 281
Table 9.2: Immovable property tax bases utilized in the OECD-10 countries
Land Land and buildings/improvements
Buildings/improvements only
Australia X X
Canada X
Ireland X
Japan X
Netherlands X
New Zealand X X
Spain X
Switzerland(a)
United Kingdom X X
United States(b) (a) Most canton levy land tax on the value of property as shown in the local land register. (b) Methods for assessing the value of a property vary depending on the jurisdiction. Source: Various, see Chapter 1 (1.4.1). Appendix table 9.1.1 describes in more detail the various taxes levied on immovable property. Some of the key points that can be drawn from the analysis of these taxes are:
• the bases that the taxes are levied on and the bases of assessment vary between countries, between different taxes levied in a country and between different jurisdictions within countries; and
• exemptions are quite common and typically relate to how the property is used.
Overall, Australia’s taxes on immovable property seem to be broadly comparable with many of the other OECD-10, but the OECD-10 overall tends to rely more on these taxes than the remainder of the OECD-30.
9.4 RECURRENT TAXES ON NET WEALTH
Recurrent taxes on net wealth are usually annual taxes based on a percentage of the taxpayer’s financial and real assets after the deduction of financial liabilities.
This type of tax is likely to have significant compliance costs for taxpayers requiring them to calculate annually the change in the total value of their assets and financial liabilities (such as outstanding loans). Records of these valuations and a system of verifying them are necessary.
Australia is one of seven OECD-10 countries that do not levy a recurrent net wealth tax. Only Canada, Spain and Switzerland levy this type of property tax.
Of these three countries, Switzerland relies the most heavily on these taxes (1.4 per cent of GDP), while for Canada and Spain they are a relatively small proportion of their tax mix.
International comparison of Australia’s taxes
Page 282
Chart 9.4: Recurrent wealth tax burden OECD-10, taxation revenue as a proportion of GDP, ordered by tax burden, 2003
0.0
0.5
1.0
1.5
Irela
nd
Japa
n
Net
herla
nds
NZ
UK
US
Spa
in
Can
ada
Sw
itzer
land
0.0
0.5
1.0
1.5
Unweighted average
Aus
tral
ia
Per cent of GDP Per cent of GDP
Source: OECD Revenue Statistics, 2005.
9.5 ESTATE, INHERITANCE AND GIFT TAXES
Australia is one of two OECD-10 countries that do not impose any estate, inheritance and gift taxes.
Of the OECD-10, Japan, the Netherlands and the United States rely most heavily on these taxes. Even for these countries, they are not a significant part of their tax base, accounting for around 0.3 per cent of GDP.
New Zealand collected approximately NZ$2 million from its gift tax in 2003, which is less than 0.01 per cent of its GDP.
Chapter 9: Property and transaction taxation
Page 283
Chart 9.5: Estate, gift and inheritance tax burden OECD-10, taxation revenue as a proportion of GDP, ordered by tax burden, 2003
0.0
0.2
0.4
0.6
Can
ada
NZ
Irela
nd
Spa
in
Sw
itzer
land UK
Japa
n
Net
herla
nds
US
0.0
0.2
0.4
0.6
Unweighted average
Aus
tral
ia
Per cent of GDP Per cent of GDP
Source: OECD Revenue Statistics, 2005. In Canada, these taxes are not directly levied, but they are effectively imposed through deemed disposition provisions in income tax legislation.
Table 9.3: Summary of estate, inheritance and gift taxes in the OECD-10 countries Estate/Inheritance tax Gift tax
Australia
Canada(a)
Ireland X X
Japan X X
Netherlands X X
New Zealand X
Spain X X
Switzerland X X
United Kingdom X
United States X X (a) While Canada does not levy any estate, inheritance or gift taxes, they are effectively imposed through deemed disposition
provisions in income tax legislation. Source: Various, see Chapter 1 (1.4.1).
International comparison of Australia’s taxes
Page 284
Table 9.4: Tax rates and examples of exemptions/concessions Rates Examples of exemptions/concessions applied Australia n/a n/a
Canada n/a n/a
Ireland 20 per cent (Capital acquisitions tax). Gifts between spouses, gifts and inheritances to charities.
Japan Rates vary depending on the value of the gift/inheritance. Rates vary between 10 per cent-50 per cent (Inheritance tax and Gift tax).
Properties received by a person engaged in religious, charitable, scientific or other activities of public welfare.
Netherlands Levied at a progressive rate and depend on the relationship between the donor/donee. Rates vary between 5 per cent-68 per cent (Inheritance tax and Gift tax).
Deductions are allowed for spouses and children.
New Zealand Levied at a progressive rate, varying between 0 per cent-25 per cent (Gift duty).
Gifts of less than NZ$2,000 in a year, gifts to charities and gratuities.
Spain Vary as levied by sub-national governments. The default rate for all regions varies from 7.65 per cent to 34 per cent depending on the taxable amount.
Deductions available for family members.
Switzerland Varies between cantons — most cantons levy inheritance and gift taxes.
In Zurich (for example), spouses, same sex couples and descendants are exempt.
United Kingdom Nil rate up to £275,000, 40 per cent for chargeable transfers and 20 per cent for chargeable lifetime transfers (Inheritance tax).
Transfers between spouses, donations to charity and political parties.
United States Ranges between 18 per cent and 46 per cent depending on the taxable amount (Unified Estate and Gift Tax System).
Bequests to charities, unlimited marital deduction is allowed for bequests to a surviving spouse.
Source: Various, see Chapter 1 (1.4.1). Appendix table 9.1.2 describes in more detail the estate, inheritance and gift taxes levied in the OECD-10 countries. Some of the key points from the analysis of these taxes are:
• estate, inheritance and gift taxes tend to be levied progressively in relation to the value of the inheritance/gift received;
• exemptions/deductions/concessions are common, especially for family members; and
• exemptions generally apply to donations made to organisations perceived to act in the public interest (that is, charities, religious organisations and government/political entities).
9.6 TAXES ON FINANCIAL AND CAPITAL TRANSACTIONS
Taxes on financial and capital transactions are defined by the OECD as taxes on transactions such as:
• the issue, transfer, purchase and sale of securities;
• cheques; and
• specific legal transactions such as validation of contracts and the sale of immovable property.
Chapter 9: Property and transaction taxation
Page 285
In Australia, examples of such taxes would include stamp duties on residential conveyances, non-residential conveyances, mortgages, leases, shares, rental arrangements and other products.
Australia has the highest reliance on transaction taxes such as stamp duties on conveyances (1.6 per cent of GDP) of the OECD-10 (unweighted average of 0.7 per cent).
Of the other OECD-10 countries, Spain (1.3 per cent) and Ireland (1.2 per cent) also rely relatively heavily on these taxes compared to the other OECD-10 countries.
Again, as noted earlier, there are classification issues when the OECD tax data are disaggregated.
Some sub-national governments in both Canada and the United States impose taxes on the transfer of real estate, but revenues from these taxes are not reported under this sub-category.
• For Canada, revenues from land transfer taxes are reported under the ‘other (non-recurrent) property tax’ category in the OECD’s Revenue Statistics 2005 Edition (4520). Statistics Canada has advised that land transfer taxation revenue totalled C$1.9 billion in 2004 (around 0.1 per cent of GDP).
• For the United States, revenues from real estate transfer taxes are reported under another category in the OECD’s Revenue Statistics 2005 Edition — ‘recurrent taxes on the use of goods or on the permission to perform activities’ (5213). Revenue collections from document and stock transfer taxes for state governments only were US$7.9 billion in 2004 (around 0.1 per cent of GDP).
New Zealand imposes two financial and capital transaction duties — cheque duty and an approved issuer levy (approved issuers are required to pay a levy for the right to issue securities that are subject to a zero rate of non-resident withholding tax). For 2003, New Zealand reported revenue collections of NZ$56 million (less than 0.1 per cent of GDP) under this sub-category.
International comparison of Australia’s taxes
Page 286
Chart 9.6: Transaction tax burden OECD-10, taxation revenue as a proportion of GDP, ordered by tax burden, 2003
0.0
0.6
1.2
1.8C
anad
a
NZ
US
Japa
n
Sw
itzer
land UK
Net
herla
nds
Irela
nd
Spa
in
0.0
0.6
1.2
1.8
Unweighted average
Per cent of GDP Per cent of GDP
Aus
tral
ia
Source: OECD Revenue Statistics, 2005. Note: Revenues from Bank Accounts Debits tax (BAD tax) is included in the total figure for Australia. Under the Intergovernmental Agreement on the Reform of Commonwealth-State Financial Relations, all States and Territories abolished BAD tax by 1 July 2005 (New South Wales abolished BAD tax on 1 January 2002). The most significant component of this category of taxes for Australia is the State and Territory stamp duties on conveyances (taxes on the sale of land and buildings).
• In 2003-04, around 80 per cent of the revenue from taxes on financial and capital transactions was attributable to stamp duties on conveyances for Australia. Revenue collections from stamp duties on conveyances vary with property values and with the level of market activity, so this revenue source can be subject to greater variability than other sources.
• Revenue from stamp duties on conveyances of real property makes up the majority of conveyance duty revenue collections for the Australian States and Territories.
Apart from New Zealand, all other OECD-10 countries levy taxes on the transfer of real estate.
Appendix table 9.1.3 provides some details of these taxes in the OECD-10. Again, comparable information on these types of taxes is not readily available and the information in this table must be treated with caution as it has not been verified with the individual countries.
Chapter 9: Property and transaction taxation
Page 287
Table 9.5: Level of government levying taxes on the transfer of real estate Australia State Canada Provincial and Local Ireland National Japan National and Local (prefectures) Netherlands National New Zealand n/a Spain Local (Autonomous Communities) Switzerland Canton and Local (Communes) United Kingdom National United States State and Local (County)
Source: Various, see Chapter 1 (1.4.1).
Chart 9.7: Top tax rate applied on the transfer of real estate OECD-10, 2005
0
1
2
3
4
5
6
7
8
9
10
NZ
Can
ada
US
Sw
itzer
land
Japa
n
UK
Net
herla
nds
Spai
n
Irela
nd
0
1
2
3
4
5
6
7
8
9
10Per cent Per cent
Aus
tral
ia
Source: Various, see Chapter 1 (1.4.1). Australia’s top rate for stamp duty on conveyances (7 per cent) is the equal second highest of the OECD-10.
• The top conveyance duty rate of 7 per cent is the marginal rate applying to residential conveyances over A$3 million in New South Wales.
In addition to stamp duty on conveyances, the Australian States and Territories also levy a number of other financial transaction taxes, including stamp duties on mortgages, leases, shares and rental arrangements. Nearly all other OECD-10 countries also levy taxes on one or more of these transactions (Appendix table 9.1.4).
The goods and services tax (GST) was intended to replace a majority of these financial and capital transactions taxes in Australia. In 2005, the Australian Government proposed a timetable for the elimination of the remaining State and Territory taxes listed in the Intergovernmental Agreement on the Reform of Commonwealth-State Financial Relations (the agreement which provides for all GST revenue to be paid to the States and Territories).
International comparison of Australia’s taxes
Page 288
• These taxes are stamp duties on mortgages, leases, cheques, shares, rental arrangements and business conveyances.
At the time of writing this report, complete agreement has not been reached between the Australian Government and all the States and Territories on the timetables for abolishing these taxes.
• Nonetheless, some States and Territories intend to abolish a number of these taxes over the next few years.
It is possible that in many OECD countries other general taxes, like VAT or capital gains tax, are applied to these transactions. For example, tax rates on the transfer of real estate in other countries might be quite low as other taxes that apply to the same base are relatively high, or taxes may be calculated on a VAT inclusive price. In addition, the interactions between these taxes could vary significantly from country to country and they have not been fully explored here. As a result, the total tax burden on financial and capital transactions may vary significantly from the revenue collections of financial and capital transaction taxes in OECD countries.
Chapter 9: Property and transaction taxation
Page 289
REFERENCES
Australian Bureau of Statistics, 2005, Taxation Revenue 2003-04 (Reissue), cat. no. 5506.0, ABS, Canberra.
Bird, R M and Slack, E 2004, International Handbook of Land and Property Taxation, Edward Elgar, Cheltenham, United Kingdom.
Brown, P K and Hepworth, M A 2002, A Study of European Land Tax Systems, Lincoln Institute of Land Policy, Cambridge M A, United States of America.
Franzsen, R C D and McCluskey, W J 2005, An Exploratory Overview of Property Taxation in the Commonwealth of Nations, Lincoln Institute of Land Policy, Cambridge MA, United States of America.
Greater Zurich Area, Swiss Tax System, viewed 30 March 2006, www.greaterzuricharea.ch/default_en.asp?pgn=/content/03/03_005en.asp.
International Bureau of Fiscal Documentation.
Location: Switzerland 2002, The Advantages of the Swiss Tax System 2002 Edition, Location: Switzerland, Zurich.
Lymer, A and Oats, L 2005, Taxation: Policy and Practice 12th Edition 2005-06, Fiscal Publications, Birmingham.
Ministry of Finance 2005, An Outline of Japanese Taxes 2005, The Japanese Government, Tokyo.
Ministry of Finance 2005, Taxation in the Netherlands 2005, The Hague.
Ministry of Industry, Tourism and Trade 2005, A guide to business in Spain, Madrid.
National Association of Realtors 2005, Summary of real estate transfer taxes by State, viewed 31 March 2006, www.realtor.org/SG3.nsf/files/TransferTaxRates(8-05).pdf/$FILE/TransferTaxRates(8-05).pdf.
New South Wales Treasury 2005, Interstate Comparison of Taxes 2005-2006, NSW Treasury, Sydney.
Oasis, Stamp duty in Ireland, Irish eGovernment, viewed 31 March 2006, oasis.gov.ie/housing/buying_a_house_or_flat/stamp_duty.html?CONTACTSID=46efb796817bb53985193b99a61daa69.
OECD 2005, Revenue Statistics 1965-2004, OECD, Paris.
PricewaterhouseCoopers Canada 2005, Tax Facts and Figures — for Individuals and Corporations — Canada 2005, PwC, Canada.
International comparison of Australia’s taxes
Page 290
APP
END
IX 9
.1: T
AXE
S O
N IM
MO
VAB
LE P
RO
PER
TY
Cou
ntry
Ta
x R
ate
Bas
e Ex
empt
ions
Le
vel o
f go
vern
men
t O
ther
Aus
tralia
La
nd ta
x R
ates
are
pr
ogre
ssiv
e an
d va
ry a
cros
s ju
risdi
ctio
ns.
Land
— u
nim
prov
ed v
alue
. A
prin
cipa
l pla
ce o
f res
iden
ce is
gen
eral
ly
exem
pt, a
s is
land
use
d fo
r prim
ary
prod
uctio
n.
Land
ow
ned
by re
ligio
us b
odie
s an
d sc
hool
s.
Sta
te
Gen
eral
ly, l
iabi
lity
rest
s pr
imar
ily w
ith th
e ow
ner a
t a
parti
cula
r poi
nt in
tim
e.
R
ates
V
ary
acro
ss
juris
dict
ions
. V
arie
s ac
ross
juris
dict
ions
— la
nd
or la
nd a
nd im
prov
emen
ts.
Var
y ac
ross
juris
dict
ions
— c
omm
on
exem
ptio
ns in
clud
e pu
blic
ly o
wne
d la
nd,
publ
ic h
ospi
tals
, lib
rarie
s, c
emet
erie
s,
char
ities
, chu
rch
land
s, u
nive
rsiti
es, s
choo
ls
and
fore
ign
emba
ssie
s.
Loca
l
Can
ada
Pro
perty
tax
Rat
es v
ary
by c
lass
of
pro
perty
and
fro
m m
unic
ipal
ity
to m
unic
ipal
ity.
Land
and
impr
ovem
ents
. E
xem
ptio
ns in
clud
e ch
urch
es, c
emet
erie
s,
Indi
an la
nds,
pub
lic h
ospi
tals
, cha
ritab
le
inst
itutio
ns a
nd e
duca
tiona
l ins
titut
ions
.
Loca
l
Irela
nd
Rat
es
Fixe
d ev
ery
year
by
loca
l aut
horit
ies
as a
mul
tiple
of t
he
rate
able
val
ue o
f th
e pr
oper
ty.
Land
and
impr
ovem
ents
— ta
xabl
e va
lue
is b
ased
on
annu
al re
ntal
va
lue
of th
e ra
teab
le p
rope
rty.
Dom
estic
and
agr
icul
tura
l pro
perty
is
outs
ide
the
scop
e of
the
tax.
C
omm
on e
xem
ptio
ns in
clud
e pr
oper
ty u
sed
excl
usiv
ely
for t
he p
urpo
se o
f pub
lic re
ligio
us
wor
ship
, art
galle
ries,
mus
eum
s, a
nd
libra
ries,
pro
perty
use
d fo
r edu
catio
nal
purp
oses
, bur
ial g
roun
ds o
r cre
mat
oriu
ms.
Loca
l A
loca
l tax
on
the
occu
patio
n of
imm
ovab
le
prop
erty
for n
on-r
esid
entia
l is
pay
able
by
the
occu
pier
.
Japa
n P
rope
rty ta
x Th
e st
anda
rd ra
te
is 1
.4 p
er c
ent,
max
imum
rate
is
2.1
per
cen
t.
Land
, bui
ldin
gs a
nd d
epre
ciab
le
busi
ness
ass
ets.
Th
e ta
x ba
se fo
r lan
d an
d bu
ildin
gs
is th
eir v
alue
ass
esse
d by
m
unic
ipal
ities
, bas
ed o
n m
arke
t pr
ices
.
Sta
ndar
d ex
empt
ions
are
ava
ilabl
e fo
r lan
d (o
f val
ue u
p to
¥30
0,00
0) a
nd h
ousi
ng
(val
ue u
p to
¥20
0,00
0).
Pro
perty
use
d as
pub
lic ro
ads
or c
emet
erie
s,
or fo
r edu
catio
nal,
relig
ious
, or s
ocia
l wel
fare
is
exe
mpt
.
Loca
l
C
ity p
lann
ing
tax
Max
imum
of
0.3
per c
ent.
Impo
sed
on th
e ow
ners
of l
and
and
build
ings
loca
ted
with
in a
n ur
ban
prom
otio
n ar
ea. A
ppra
ised
val
ue
for p
rope
rty ta
xes
is u
sed.
Lo
cal
May
be
impo
sed
by c
ities
, to
wns
and
vill
ages
un
derta
king
pro
ject
s un
der
the
City
Pla
nnin
g La
w.
La
nd d
evel
opm
ent
tax
At t
he d
iscr
etio
n of
lo
cal a
utho
ritie
s.
Impo
sed
on d
evel
oper
s of
land
and
is
bas
ed o
n th
e de
velo
ped
area
.
Loca
l
Chapter 9: Property and transaction taxation
Page 291
App
endi
x 9.
1: T
axes
on
imm
ovab
le p
rope
rty
(con
tinue
d)
Cou
ntry
Ta
x R
ate
Bas
e Ex
empt
ions
Le
vel o
f go
vern
men
t O
ther
Net
herla
nds
Imm
ovab
le
prop
erty
taxe
s R
ate
diffe
rs fo
r ea
ch m
unic
ipal
ity.
Diff
eren
t rat
es m
ay
appl
y fo
r co
mm
erci
al p
rope
rty
and
priv
ate
prop
erty
.
Land
and
impr
ovem
ents
. E
xem
ptio
ns in
clud
e na
tura
l site
s, p
ublic
ro
ads,
pub
lic w
ater
way
s, p
rope
rty m
ainl
y us
ed fo
r pub
lic w
orsh
ip, f
orei
gn e
mba
ssie
s an
d co
nsul
ates
, pub
lic g
arde
ns, p
ublic
pa
rks,
cem
eter
ies,
and
cre
mat
oriu
ms.
Loca
l Th
e ta
x co
nsis
ts o
f:
(1)
a pa
rt le
vied
on
owne
rs
of im
mov
able
pro
perty
; an
d (2
) a
part
levi
ed o
n th
e us
ers
of im
mov
able
pr
oper
ty.
New
Zea
land
R
ates
V
arie
s de
pend
ing
on th
e ty
pe o
f rat
e im
pose
d.
Var
ies
— th
ere
are
four
sys
tem
s of
gen
eral
ratin
g. T
hey
incl
ude
by
capi
tal (
land
and
impr
ovem
ents
) va
lue,
by
unim
prov
ed la
nd v
alue
, by
the
annu
al re
ntal
val
ue o
f the
pr
oper
ty a
nd b
y th
e ar
ea s
yste
m.
Exe
mpt
ions
incl
ude
prop
erty
use
d fo
r re
ligio
us, c
harit
able
and
edu
catio
nal
purp
oses
; her
itage
pro
perty
; com
mun
ity
land
; and
Mao
ri an
d bu
rial g
roun
ds.
Loca
l
Spa
in
Taxe
s on
real
es
tate
G
ener
al ta
x ra
tes
are
0.4
per c
ent f
or
urba
n pr
oper
ty a
nd
0.3
per c
ent f
or ru
ral
prop
erty
, but
hig
her
rate
s m
ay a
pply
.
Land
and
bui
ldin
gs.
Exe
mpt
ions
incl
ude
prop
erty
ow
ned
by th
e ch
urch
and
Red
Cro
ss; d
iplo
mat
ic p
rem
ises
; sc
hool
s.
Loca
l Th
e ta
xabl
e ba
se is
the
cada
stra
l val
ue. T
he
cada
stra
l val
ue is
upd
ated
ev
ery
eigh
t yea
rs w
ith
refe
renc
e to
the
mar
ket
valu
e of
the
prop
erty
, in
clud
ing
the
valu
e of
land
an
d bu
ildin
gs.
Sw
itzer
land
La
nd ta
x R
ates
var
y be
twee
n 0.
3 pe
r cen
t and
4
per c
ent.
The
appl
icat
ion
of th
e ta
x ca
n va
ry
acro
ss ju
risdi
ctio
ns. N
on-fa
rm
prop
ertie
s ar
e us
ually
ass
esse
d w
ith
resp
ect t
o th
eir m
arke
t val
ue,
whe
reas
farm
and
fore
stry
pro
perti
es
mea
sure
thei
r ear
ning
pow
er.
C
anto
n/Lo
cal
Prim
arily
a c
omm
unal
(lo
cal)
tax.
Uni
ted
Kin
gdom
B
usin
ess
rate
s Fo
r the
yea
r end
ing
31 M
arch
200
6,
the
rate
is
42.2
per
cen
t in
Eng
land
(sim
ilar
rate
s ap
ply
in
Sco
tland
and
W
ales
).
Land
and
impr
ovem
ents
(c
omm
erci
al o
nly)
. E
xem
ptio
ns in
clud
e ag
ricul
tura
l lan
d an
d bu
ildin
gs; p
lace
s of
pub
lic w
orsh
ip;
prop
ertie
s oc
cupi
ed b
y ch
arita
ble
and
spor
ting
orga
nisa
tions
; and
dip
lom
atic
pr
emis
es.
Nat
iona
l Th
e ta
x is
pay
able
by
the
occu
pier
. R
atea
ble
valu
es, w
hich
are
as
sess
ed e
very
five
yea
rs,
are
curr
ently
bas
ed o
n m
arke
t ren
ts o
n 1
Apr
il 20
03.
International comparison of Australia’s taxes
Page 292
App
endi
x 9.
1: T
axes
on
imm
ovab
le p
rope
rty
(con
tinue
d)
Cou
ntry
Ta
x R
ate
Bas
e Ex
empt
ions
Le
vel o
f go
vern
men
t O
ther
Uni
ted
Kin
gdom
(c
ontin
ued)
C
ounc
il ta
x R
ates
are
set
by
each
loca
l go
vern
men
t.
Bui
ldin
gs (r
esid
entia
l onl
y).
Exe
mpt
ions
incl
ude
prop
ertie
s th
at a
re
owne
d by
cha
rity,
kep
t for
occ
upat
ion
by
min
iste
rs o
f rel
igio
n, o
ccup
ied
by s
tude
nts;
an
d oc
cupi
ed o
r man
aged
by
an e
duca
tiona
l es
tabl
ishm
ent o
r cha
ritab
le b
ody.
Loca
l Th
e ta
x is
pay
able
by
the
occu
pier
.
Uni
ted
Sta
tes
Rea
l est
ate
ta
xes
Var
ies
acro
ss
juris
dict
ions
. M
etho
ds fo
r ass
essi
ng th
e va
lue
of a
pro
perty
var
y de
pend
ing
on
the
juris
dict
ion.
Lo
cal
Sou
rce:
Var
ious
, see
Cha
pter
1 (1
.4.1
).
Chapter 9: Property and transaction taxation
Page 293
APP
END
IX 9
.2: E
STA
TE, I
NH
ERIT
AN
CE
AN
D G
IFT
TAXE
S
Cou
ntry
Ta
x R
ate
Bas
e Ex
empt
ion
Leve
l of
gove
rnm
ent
Add
ition
al in
form
atio
n
Aus
tralia
A
ustra
lia d
oes
not i
mpo
se e
stat
e, in
herit
ance
or g
ift ta
xes.
Can
ada
No
Can
adia
n ju
risdi
ctio
n im
pose
s a
gift
or in
herit
ance
tax
per s
e. T
hey
are
effe
ctiv
ely
impo
sed
thro
ugh
deem
ed d
ispo
sitio
n pr
ovis
ions
in
inco
me
tax
legi
slat
ion.
D
eem
ed
disp
ositi
on
thro
ugh
a gi
ft
As
per i
ncom
e ta
x ra
te.
A p
erso
n w
ho g
ifts
prop
erty
to
anot
her i
s de
emed
to h
ave
rece
ived
pr
ocee
ds e
qual
to it
s fa
ir m
arke
t va
lue.
The
dee
med
pro
ceed
s m
ay
caus
e th
e do
nor t
o re
cogn
ise
inco
me,
re
capt
ured
dep
reci
atio
n or
cap
ital
gain
s.
Dep
ends
on
the
prop
erty
invo
lved
. Als
o, a
sp
ouse
may
tran
sfer
pro
perty
to th
e ot
her
spou
se w
ithou
t attr
actin
g lia
bilit
y.
D
eem
ed
disp
ositi
on
thro
ugh
deat
h
As
per i
ncom
e ta
x ra
te.
Sim
ilar t
o ab
ove.
The
dec
ease
d is
de
emed
to h
ave
disp
osed
of a
ll pr
oper
ty o
wne
d im
med
iate
ly b
efor
e th
e tim
e of
dea
th. N
ote
that
dee
med
ca
pita
l gai
n is
onl
y th
e in
crea
se in
va
lue
of a
sset
s, n
ot th
e to
tal v
alue
.
A s
pous
e m
ay tr
ansf
er p
rope
rty to
the
othe
r sp
ouse
with
out a
ttrac
ting
liabi
lity.
Irela
nd
Cap
ital
acqu
isiti
ons
tax
A s
ingl
e ra
te o
f 20
per
cen
t, w
hich
ap
plie
s to
any
ac
cum
ulat
ed g
ifts
and
inhe
ritan
ces
over
the
rele
vant
cl
ass
thre
shol
d.
Levi
ed o
n th
e re
ceip
t of g
ifts,
or o
n th
e su
cces
sor o
f pro
perty
pas
sing
on
dea
th. T
he ta
xabl
e va
lue
is th
e m
arke
t val
ue o
n th
e da
te o
f the
gift
or
suc
cess
ion.
A n
umbe
r of e
xem
ptio
ns in
clud
ing,
but
not
lim
ited
to, g
ifts
pass
ing
betw
een
spou
ses,
gi
fts a
nd in
herit
ance
s to
cha
rity;
sm
all g
ifts
up to
€1,
270
per y
ear,
gifts
and
inhe
ritan
ces
of li
fe in
sura
nce
polic
ies.
Nat
iona
l
International comparison of Australia’s taxes
Page 294
App
endi
x 9.
2: E
stat
e, in
herit
ance
and
gift
taxe
s (c
ontin
ued)
C
ount
ry
Tax
Rat
e B
ase
Exem
ptio
n Le
vel o
f go
vern
men
t A
dditi
onal
info
rmat
ion
Japa
n In
herit
ance
tax
Bet
wee
n 10
per
cen
t an
d 50
per
cen
t de
pend
ing
on th
e si
ze o
f the
in
herit
ance
.
Impo
sed
on th
e to
tal v
alue
of a
ll pr
oper
ties
acqu
ired
thro
ugh
an
inhe
ritan
ce o
r a b
eque
st (l
ess
liabi
litie
s an
d fu
nera
l exp
ense
s).
Val
uatio
n of
pro
perti
es is
bas
ed o
n m
arke
t pric
e.
Exe
mpt
ions
incl
ude,
but
are
not
lim
ited
to,
life
and
pers
onal
acc
iden
t ins
uran
ce
proc
eeds
; ret
irem
ent a
nd s
imila
r ben
efits
; an
d pr
oper
ties
rece
ived
by
a pe
rson
en
gage
d in
relig
ious
, cha
ritab
le, s
cien
tific
or
othe
r act
iviti
es fo
r pub
lic w
elfa
re.
Nat
iona
l G
ifts
with
in th
ree
year
s be
fore
dea
th a
re in
clud
ed in
th
e ta
xabl
e ba
se, b
ut a
ny
gift
tax
paya
ble
is c
redi
ted
agai
nst t
he in
herit
ance
tax.
G
ift ta
x B
etw
een
10 p
er c
ent
and
50 p
er c
ent
depe
ndin
g on
the
size
of t
he g
ift.
Impo
sed
on p
rope
rty g
iven
as
a gi
ft.
Exe
mpt
ions
incl
ude,
but
are
not
lim
ited
to,
gifts
from
a c
orpo
ratio
n; s
ums
rece
ived
by
depe
ndan
ts fo
r liv
ing
and
educ
atio
nal
expe
nses
; pro
perti
es re
ceiv
ed b
y a
pers
on
enga
ged
in re
ligio
us, c
harit
able
, sci
entif
ic o
r ot
her a
ctiv
ities
for p
ublic
wel
fare
; and
po
litic
al c
ontri
butio
ns.
Nat
iona
l
Net
herla
nds
Suc
cess
ion
duty
Le
vied
at a
pr
ogre
ssiv
e ra
te
(bet
wee
n 5
per c
ent
and
68 p
er c
ent)
depe
ndin
g on
the
prox
imity
of t
he
rela
tions
hip
betw
een
the
dece
ased
/don
or
and
the
valu
e of
the
inhe
ritan
ce.
Impo
sed
if pr
oper
ty is
acq
uire
d by
in
herit
ance
or b
y gi
ft an
d th
e de
ceas
ed/d
onor
was
/is a
resi
dent
of
the
Net
herla
nds.
Ded
uctio
ns a
re a
llow
ed fo
r spo
uses
and
ch
ildre
n. G
ifts
to c
erta
in m
useu
ms.
N
atio
nal
Levi
ed o
n th
e be
nefic
iary
/don
ee.
New
Zea
land
G
ift d
uty
Mar
gina
l rat
es ra
nge
from
0 p
er c
ent t
o 25
per
cen
t de
pend
ing
on th
e va
lue
of th
e gi
ft.
Pay
able
on
gifts
of a
ll pr
oper
ty in
N
ew Z
eala
nd a
nd g
ifts
of p
rope
rty
situ
ated
out
side
New
Zea
land
if th
e do
nor i
s do
mic
iled
in N
ew Z
eala
nd.
Exe
mpt
ions
incl
ude,
but
are
not
lim
ited
to
gifts
of l
ess
than
NZ$
2,00
0 in
agg
rega
te fo
r on
e ca
lend
ar y
ear;
gifts
to m
aint
ain
educ
atio
n of
rela
tives
; gift
s to
cha
ritie
s an
d gr
atui
ties.
Nat
iona
l
Spa
in
Inhe
ritan
ce a
nd
gift
tax
Var
ies
depe
ndin
g on
re
gion
. The
def
ault
rate
for a
ll re
gion
s va
ries
from
7.
65 p
er c
ent t
o 34
per
cen
t de
pend
ing
on th
e ta
xabl
e am
ount
.
Tran
sfer
red
asse
ts a
re v
alue
d at
th
eir f
air m
arke
t val
ue.
Ded
uctio
ns a
vaila
ble
for f
amily
mem
bers
. A
uton
omou
s co
mm
uniti
es
A re
cipi
ent w
ho is
a
resi
dent
of S
pain
is li
able
to
this
tax
with
rega
rd to
pr
oper
ty in
Spa
in o
r abr
oad,
ac
quire
d th
roug
h a
grat
uito
us tr
ansf
er.
Non
-res
iden
ts a
re s
ubje
ct
to th
is ta
x w
ith re
gard
to
any
asse
ts lo
cate
d in
S
pain
.
Chapter 9: Property and transaction taxation
Page 295
App
endi
x 9.
2: E
stat
e, in
herit
ance
and
gift
taxe
s (c
ontin
ued)
C
ount
ry
Tax
Rat
e B
ase
Exem
ptio
n Le
vel o
f go
vern
men
t A
dditi
onal
info
rmat
ion
Sw
itzer
land
In
herit
ance
and
gi
ft ta
xes
The
effe
ctiv
e ta
x bu
rden
var
ies
betw
een
cant
ons,
bu
t usu
ally
is b
ased
on
the
degr
ee o
f re
latio
nshi
p an
d/or
th
e re
ceiv
ed
amou
nt. R
ates
ra
nge
from
10
per
cen
t to
50 p
er c
ent.
For t
ax p
urpo
ses,
ther
e is
gen
eral
ly
no d
istin
ctio
n be
twee
n in
herit
ance
s an
d gi
fts. T
he ri
ght t
o le
vy in
herit
ance
an
d gi
ft ta
xes
on m
ovab
le p
rope
rty is
le
ft to
the
cant
on in
whi
ch th
e de
scen
dant
had
thei
r las
t res
iden
ce,
and
to th
e ca
nton
in w
hich
the
dono
r ha
s th
eir r
esid
ence
, res
pect
ivel
y.
For e
xam
ple,
in th
e ca
nton
of Z
uric
h,
spou
ses,
sam
e-se
x co
uple
s an
d de
scen
dant
s ar
e ex
empt
.
Can
tons
M
ost c
anto
ns le
vy
inhe
ritan
ce a
nd g
ift ta
xes.
Uni
ted
Kin
gdom
In
herit
ance
tax
A n
il ra
te a
pplie
s up
to
£27
5,00
0. A
bove
th
is a
mou
nt, t
he ra
te
is 4
0 pe
r cen
t for
ch
arge
able
tran
sfer
s an
d 20
per
cen
t for
ch
arge
able
life
time
trans
fers
.
Levi
ed o
n th
e tra
nsfe
r of a
ll pr
oper
ty
pass
ing
on d
eath
(cha
rgea
ble
trans
fers
).
Exe
mpt
ions
incl
ude,
but
are
not
lim
ited
to,
trans
fers
bet
wee
n sp
ouse
s, re
gula
r gift
s,
gifts
up
to £
3,00
0 in
a ta
x ye
ar, a
nd
dona
tions
to c
harit
y an
d po
litic
al p
artie
s.
Nat
iona
l It
is a
lso
levi
ed o
n ce
rtain
gi
fts m
ade
with
in th
e se
ven
year
s be
fore
the
deat
h of
a p
erso
n. It
is
levi
ed o
n w
orld
wid
e pr
oper
ty o
f dom
icile
d in
divi
dual
s an
d tru
sts.
N
on-d
omic
iled
indi
vidu
als
are
liabl
e to
tax
only
on
asse
ts s
ituat
ed in
the
Uni
ted
Kin
gdom
.
Uni
ted
Sta
tes
Uni
fied
Est
ate
and
Gift
Tax
S
yste
m
Ran
ges
betw
een
18 p
er c
ent a
nd
46 p
er c
ent
depe
ndin
g on
the
taxa
ble
amou
nt.
Levi
ed o
n th
e ac
cum
ulat
ive
tota
l va
lue
of a
ll tra
nsfe
rs m
ade
by a
n in
divi
dual
dur
ing
life
and
at th
e tim
e of
dea
th. A
pplie
s to
all
Uni
ted
Sta
tes
citiz
ens
and
fore
ign
natio
nals
who
are
U
nite
d S
tate
s re
side
nts
at th
e tim
e of
de
ath.
App
lies
also
to n
on-r
esid
ents
on
pro
perty
that
is d
eem
ed to
hav
e a
Uni
ted
Sta
ted
loca
tion.
Pro
perty
is
valu
ed a
t the
fair
mar
ket v
alue
at
time
of d
eath
.
The
valu
e of
the
gros
s es
tate
is re
duce
d by
: (1
) ex
pens
es a
nd lo
sses
; (2
) m
ortg
ages
and
inde
bted
ness
; (3
) ce
rtain
taxe
s im
pose
d by
Uni
ted
Sta
tes
stat
es o
r for
eign
cou
ntrie
s on
tran
sfer
s m
ade
for p
ublic
, cha
ritab
le o
r rel
igio
us
purp
oses
; and
(4
) be
ques
ts to
cha
ritie
s. A
lso,
an
unlim
ited
mar
ital d
educ
tion
is a
llow
ed fo
r be
ques
ts to
a s
urvi
ving
spo
use.
An
excl
usio
n ap
plie
s to
gift
s up
to th
e va
lue
of U
S$1
2,00
0 pe
r don
ee in
one
yea
r.
A
lso
impo
ses
a ge
nera
tion
skip
ping
tran
sfer
tax
(GS
TT) o
n tra
nsfe
rs m
ade
to b
enef
icia
ries
who
are
m
ore
than
one
gen
erat
ion
youn
ger t
han
the
dono
r. N
ote:
the
esta
te ta
x an
d G
STT
are
sch
edul
ed to
be
com
plet
ely
phas
ed o
ut
by 2
010.
Sou
rce:
Var
ious
, see
Cha
pter
1 (1
.4.1
).
International comparison of Australia’s taxes
Page 296
APP
END
IX 9
.3: T
AXE
S O
N T
HE
TRA
NSF
ER O
F R
EAL
ESTA
TE
Cou
ntry
To
p ra
te(a
) Pr
ogre
ssiv
e ra
te s
truc
ture
Ex
ampl
es o
f exe
mpt
ions
(b)
Leve
l of
gove
rnm
ent
Add
ition
al in
form
atio
n
Aus
tralia
7
per c
ent
Yes
Firs
t hom
e ow
ners
can
rece
ive
disc
ount
s/ex
empt
ions
for l
ower
val
ued
prop
ertie
s.
Sta
te
Rat
es v
ary
acro
ss S
tate
s an
d Te
rrito
ries,
m
axim
um ra
tes
vary
from
3.7
5 pe
r cen
t to
7 pe
r cen
t. Th
e m
axim
um ra
te o
f 7 p
er c
ent i
s fo
r tra
nsfe
rs o
ver A
$3 m
illio
n in
N
ew S
outh
Wal
es.
Can
ada
2 pe
r cen
t Ye
s (g
ener
ally
) In
Ont
ario
, for
exa
mpl
e, a
refu
nd is
ava
ilabl
e fo
r firs
t tim
e pu
rcha
sers
of a
new
ly c
onst
ruct
ed
hom
e.
Pro
vinc
ial/L
ocal
R
ates
var
y ac
ross
pro
vinc
es (s
ix p
rovi
nces
im
pose
land
tran
sfer
taxe
s). A
few
pro
vinc
es
levy
regi
stra
tion
fees
rath
er th
an tr
ansf
er
taxe
s.
Irela
nd
9 pe
r cen
t Ye
s Fi
rst h
ome
owne
rs a
re e
xem
pt fo
r low
to
mid
-cos
t hou
ses.
N
atio
nal
Rat
es v
ary
for d
iffer
ent d
efin
ition
s of
pu
rcha
sers
. Th
e m
axim
um ra
te o
f 9 p
er c
ent i
s fo
r tra
nsfe
rs o
ver €
635,
000
for a
ll pu
rcha
sers
.
Japa
n 4
per c
ent
Nat
iona
l: va
rious
flat
am
ount
s de
pend
ing
on v
alue
. P
refe
ctur
e: fl
at 4
per
cen
t.
Exe
mpt
ions
bel
ow th
resh
old
leve
ls.
Nat
iona
l/Pre
fect
ure
Net
herla
nds
6 pe
r cen
t N
o E
xem
ptio
ns fo
r acq
uisi
tions
by
child
ren,
ac
quis
ition
s by
pub
lic o
rgan
isat
ions
, agr
icul
tura
l la
nd a
nd b
uild
ings
.
Nat
iona
l
New
Zea
land
-
- -
- -
Spa
in
7 pe
r cen
t N
o Fi
rst s
ale
of p
rope
rty (V
AT
is a
pplie
d in
stea
d).
Aut
onom
ous
com
mun
ities
Sw
itzer
land
3.
3 pe
r cen
t
C
anto
n/Lo
cal
A fe
w c
anto
ns le
vy tr
ansf
er fe
es ra
ther
than
tra
nsfe
r tax
es.
Uni
ted
Kin
gdom
4
per c
ent
Yes
Exe
mpt
ion
for n
on-r
esid
entia
l lan
d in
di
sadv
anta
ged
area
s.
Nat
iona
l H
ighe
r tax
free
thre
shol
ds fo
r res
iden
tial
prop
erty
in d
isad
vant
aged
are
as.
Uni
ted
Sta
tes
2 pe
r cen
t M
ixtu
re o
f pro
gres
sive
and
flat
st
ruct
ure.
Sta
te/L
ocal
(C
ount
y)
(a)
Top
rate
acr
oss
all j
uris
dict
ions
levy
ing
such
a ta
x.
(b)
Doe
s no
t cov
er a
ll ex
empt
ions
/con
cess
ions
. S
ourc
e: V
ario
us, s
ee C
hapt
er 1
(1.4
.1).
Chapter 9: Property and transaction taxation
Page 297
APPENDIX 9.4: EXAMPLES OF OTHER FINANCIAL AND CAPITAL TRANSACTION TAXES
Country Other types of transactions taxed Australia Mortgages, leases, share transfers, rental arrangements
Canada No examples could be found
Ireland Mortgages, leases, share transfers
Japan Transfer of mining rights, intangible property rights, leases, shares, debentures, promissory notes
Netherlands Share transfers
New Zealand Cheques
Spain Deeds, leases, moveable assets
Switzerland Shares and other financial instruments
United Kingdom Other main stamp duties beside stamp duty on property transfer, are on leases and share transactions
United States Some States levy taxes on mortgages, car hire Source: Various, see Chapter 1 (1.4.1).