How to Appeal Your Hong Kong Property Rates Assessment: A Practical Guide
📋 Key Facts at a Glance
- Strict Deadlines: Annual objections: March 17-May 31 (Form R20A); Interim objections: 28 days from notice (Form R23A); Lands Tribunal appeals: 28 days from Commissioner’s decision
- Two-Stage Process: First object to Commissioner of Rating and Valuation, then appeal to Lands Tribunal if unsatisfied
- Payment Requirement: Continue paying rates during appeal to avoid 5% surcharge on overdue amounts
- Valuation Basis: Rateable value = estimated annual rental value as at October 1, 2024 (for 2025-26 assessments)
- Legal Framework: Rating Ordinance (Cap. 116) governs all property rates appeals
Did you know that thousands of Hong Kong property owners successfully reduce their rates bills each year? If you believe your property has been overvalued, you have the legal right to challenge the assessment. This comprehensive guide walks you through the entire appeal process, from gathering evidence to navigating the Lands Tribunal, ensuring you have the knowledge to potentially save thousands in property rates.
Understanding Hong Kong Property Rates and Rateable Value
Property rates in Hong Kong are a form of taxation levied on property ownership or occupation. Unless specifically exempted under the Rating Ordinance (Chapter 116), all properties are liable for rates, calculated as a percentage of the property’s rateable value. The current rates percentage is 5% for 2024-25, though this can vary by year based on government budget decisions.
What Exactly is Rateable Value?
Rateable value represents the estimated annual rental value of a property in the open market at a specific valuation reference date. For the 2025-26 assessment period, the valuation reference date is October 1, 2024, with rateable values taking effect from April 1, 2025. The calculation assumes:
- The property is vacant and available for letting
- The tenant pays all usual tenant’s rates and taxes
- The landlord pays Government rent, repair costs, insurance, and other maintenance expenses
- The valuation reflects what the property would command in the open market
Valid Grounds for Appealing Your Assessment
You can object to your property’s rateable value if you’re aggrieved on one or more of these legal grounds:
| Ground for Appeal | What It Means |
|---|---|
| Over-valuation | Property valued above its proper rateable value (most common) |
| Wrongful Inclusion | Property included but should be omitted (e.g., exempt properties) |
| Wrongful Omission | Property omitted but should be included |
| Under-valuation | Property valued below proper rateable value (rarely used by owners) |
Common Reasons for Successful Appeals
- Comparable rental evidence showing lower market rents for similar properties
- Property defects or conditions not properly reflected in assessment
- Incorrect property particulars (size, facilities, features)
- Changes in local area affecting rental values
- Errors in application of valuation methodology
The Two-Stage Appeal Process: Step-by-Step
Stage 1: Objection to Commissioner of Rating and Valuation
This mandatory first step requires lodging a formal objection with the Commissioner. The form and deadline depend on your situation:
| Situation | Form Required | Deadline |
|---|---|---|
| Annual Revaluation Objecting to new rateable values after annual general revaluation |
Form R20A (Proposal for Alteration of Valuation List) or Form e-R20A (electronic) | March 17 to May 31 No late submissions accepted |
| Interim Valuation Objecting to provisional valuation for newly completed properties or alterations |
Form R23A (Notice of Objection to an Interim Valuation) or Form e-R23A (electronic) | Within 28 days of receiving Commissioner’s notice No extensions granted |
Stage 2: Appeal to the Lands Tribunal
If unsatisfied with the Commissioner’s decision, you may appeal to the Lands Tribunal within 28 days. This is the final administrative stage before entering the court system.
| Aspect | Details |
|---|---|
| Deadline | Within 28 days of service of Notice of Decision (Form R22A) from Commissioner |
| Form Required | Form 19 (Notice of Appeal) |
| Filing Location | Registrar of the Lands Tribunal, Ground Floor, High Court Building, 38 Queensway, Hong Kong |
| Required Documents | • Notice of Appeal (Form 19) • Copy of Commissioner’s Notice of Decision • Copy must be served on Commissioner within same 28-day period |
7-Step Guide to Successfully Appealing Your Assessment
- Step 1: Review Your Rates Demand Notice
Carefully check the rateable value, property particulars, valuation reference date (October 1, 2024 for 2025-26), and effective date. Verify details online at RVD’s Property Information Online (PIO) website or visit their enquiry counter. - Step 2: Gather Strong Comparable Evidence
Collect actual lease agreements for similar units signed within 12 months of the valuation reference date. Include market rental data, property condition photos, engineering reports, and rateable values of comparable properties. - Step 3: Determine Correct Form and Deadline
Use Form R20A/e-R20A for annual revaluations (March 17-May 31) or Form R23A/e-R23A for interim valuations (28 days from notice). - Step 4: Complete and Submit Objection Form
Download forms from RVD website or submit electronically via their “Electronic Submission of Forms” service. Include your details, property information, proposed rateable value, grounds for objection, and supporting evidence. - Step 5: Continue Paying Rates During Appeal
This is crucial! Rates must continue to be paid based on the original rateable value. Late payments incur a 5% surcharge. If successful, you’ll receive adjustments and refunds. - Step 6: Await Commissioner’s Decision
For annual objections: decision before December 1. For interim objections: within 6 months after objection period expiry. You’ll receive Notice of Decision (Form R22A). - Step 7: Consider Lands Tribunal Appeal if Necessary
If unsatisfied, file Form 19 with Lands Tribunal within 28 days of receiving Notice of Decision. Serve copy on Commissioner and pay required filing fee.
What Makes Strong Evidence for Your Appeal?
The quality of your evidence determines your success. Here’s what the RVD and Lands Tribunal value most:
| Strong Evidence (Use This) | Weak Evidence (Avoid This) |
|---|---|
| Actual rental transactions with genuine lease agreements | Subjective feelings that assessment is “too high” |
| Multiple comparable properties (3+ examples) | Single or outdated rental comparables |
| Properties similar in size, age, condition, location | Properties that aren’t genuinely comparable |
| Rentals within 6-12 months of valuation reference date | Your personal financial circumstances |
| Professional reports from qualified surveyors | Restrictions specific to your property (e.g., HOS restrictions) |
Real-World Success Stories
Case Study: Residential Apartment Reduction
Mr. Chan’s 600 sq ft Kowloon apartment received a 2025-26 rateable value of $30,000/month (up from $26,000). He researched and found three similar apartments in his building rented between September-November 2024 for $27,000-$28,000. Submitting Form e-R20A by May 15, 2025 with two tenancy agreements as evidence, he proposed $27,500. In November 2025, the Commissioner reduced it to $28,000.
Result: $2,000/month reduction = $1,200 annual rates savings (at 5% rate).
Case Study: Commercial Property Lands Tribunal Appeal
A property management company challenged a $500,000/month commercial building assessment. After Commissioner upheld the value, they filed Lands Tribunal appeal within 28 days, engaging a professional surveyor who analyzed 15 comparable transactions and proposed $450,000. The Tribunal set the value at $470,000.
Result: $30,000/month reduction = $18,000 annual savings, though professional fees were incurred.
Common Mistakes That Can Derail Your Appeal
- Missing deadlines: The #1 error – Commissioner has no discretion for late submissions
- Using wrong form: Form R20A vs R23A confusion leads to rejection
- Insufficient evidence: Objections without proper comparable rental data fail
- Stopping rate payments: Leads to 5% surcharges on overdue amounts
- Irrelevant arguments: Personal hardship isn’t relevant to market rental value
- Ignoring valuation reference date: Use evidence from around October 1, 2024 for 2025-26 assessments
✅ Key Takeaways
- Deadlines are absolute: March 17-May 31 for annual objections; 28 days for interim objections; 28 days for Lands Tribunal appeals
- Evidence is everything: Focus on objective, recent rental comparables for similar properties near the valuation reference date
- Use correct forms: Form R20A/e-R20A for annual revaluations; Form R23A/e-R23A for interim valuations
- Keep paying rates: Continue payments during appeal to avoid surcharges – refunds come if successful
- Two-stage process: Object to Commissioner first, then Lands Tribunal if unsatisfied
- Electronic submission recommended: Faster processing and confirmation via RVD website
- Professional help for complex cases: Consider surveyors for Lands Tribunal appeals or complex properties
- 2025-26 valuation date: Assessments effective April 1, 2025 are based on market values as at October 1, 2024
Successfully appealing your property rates assessment requires careful preparation, strong evidence, and strict adherence to deadlines. While the process may seem daunting, thousands of Hong Kong property owners achieve reductions each year. Start by reviewing your assessment, gathering comparable evidence, and submitting your objection before the deadline. Remember: even a modest reduction can yield meaningful savings over time.
📚 Sources & References
This article has been fact-checked against official Hong Kong government sources and authoritative references:
- Inland Revenue Department (IRD) – Official tax rates, allowances, and regulations
- Rating and Valuation Department (RVD) – Property rates and valuations
- GovHK – Official Hong Kong Government portal
- Legislative Council – Tax legislation and amendments
- RVD: Objection to Rateable Value – Official appeal procedures and forms
- Hong Kong Judiciary – Lands Tribunal – Tribunal procedures and forms
- Rating Ordinance (Cap. 116) – Primary legislation governing property rates
Last verified: December 2024 | Information is for general guidance only. Consult a qualified tax professional for specific advice.