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Understanding Property Rates Assessments in Hong Kong

In Hong Kong, property rates represent a form of taxation levied on property ownership or occupation. Unless specifically exempted under the Rating Ordinance (Chapter 116 of the Laws of Hong Kong), all properties are liable to rating assessment, with rates payable at a specified percentage of the rateable value assessed on the property.

What is Rateable Value?

Rateable value is an estimate of the annual rental value of a property in the open market as at the designated valuation reference date. It assumes that the property is vacant and available to let, based on the following conditions:

• The tenant undertakes to pay all usual tenant's rates and taxes
• The landlord undertakes to pay the Government rent, costs of repairs and insurance, and other expenses necessary to maintain the property
• The valuation reflects what the property would command in the open market

For the 2025-26 assessment period, the designated valuation reference date is October 1, 2024, with rateable values taking effect from April 1, 2025.

How Rateable Values Are Calculated

The Rating and Valuation Department (RVD) assesses rateable values primarily using the Rental Comparison Method. This involves:

• Reference to other open market rents agreed at or around the valuation date for similar properties in the locality
• Adjustments to reflect differences in size, location, facilities, standards of finish, and management
• Consideration of all factors affecting rental values: age, size, quality of finishes, location, transport facilities, and amenities
• Analysis of rental information from a large database built up from information collected from owners and tenants

Important Note: In the absence of rental evidence, alternative methods such as the Receipts and Expenditure Method or the Contractor's Method may be used.

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Grounds for Appealing Your Property Rates Assessment

Under the Rating Ordinance, you may object to your property's rateable value if you are aggrieved on one or more of the following grounds:

1. Over-valuation: The property has been valued above its proper rateable value
2. Wrongful Inclusion: The property is included in the Valuation List but should be omitted (e.g., exempt properties)
3. Wrongful Omission: A property that should be included has been omitted from the Valuation List
4. Under-valuation: The property has been valued below its proper rateable value (applicable in certain circumstances)

Common Reasons for Successful Appeals

• Comparable rental evidence showing lower market rents for similar properties
• Property defects or conditions not properly reflected in the assessment
• Incorrect property particulars (size, facilities, or features)
• Changes in the local area affecting rental values
• Errors in the application of valuation methodology

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The Two-Stage Appeal Process

Stage 1: Objection to the Commissioner of Rating and Valuation

The first step in challenging your property rates assessment is to lodge a formal objection (called a "proposal" or "objection" depending on the circumstances) with the Commissioner of Rating and Valuation. This is a mandatory prerequisite before any appeal to the Lands Tribunal.

Two Types of Objections

The type of objection form and deadline depends on your situation:

Situation	Form Required	Deadline
Annual Revaluation Objecting to new rateable values after the annual general revaluation	Form R20A (Proposal for Alteration of Valuation List) or Form e-R20A (electronic version)	March 17 to May 31 (No late submissions accepted)
Interim Valuation Objecting to a provisional valuation for newly completed properties or alterations	Form R23A (Notice of Objection to an Interim Valuation) or Form e-R23A (electronic version)	Within 28 days of receiving the Commissioner's notice (No extensions granted)

Critical Deadline Note: The Commissioner has no discretion to accept late submissions. Missing these deadlines means losing your right to object for that assessment period.

Stage 2: Appeal to the Lands Tribunal

If you remain unsatisfied with the Commissioner's decision, you may appeal to the Lands Tribunal. This is the second and final stage of the administrative appeal process before entering the court system.

Aspect	Details
Deadline	Within 28 days of service of the Notice of Decision (Form R22A) from the Commissioner
Form Required	Form 19 (Notice of Appeal)
Filing Location	Registrar of the Lands Tribunal Ground Floor, High Court Building 38 Queensway, Hong Kong Tel: 2825 4643
Fee	A fee is payable upon lodging the appeal (contact Tribunal for current fee schedule)
Required Documents	• Notice of Appeal (Form 19) • Copy of the Commissioner's Notice of Decision • Copy of appeal must also be served on the Commissioner within the same 28-day period
Governing Rules	Rating Ordinance (Cap. 116) and Lands Tribunal Rules (Cap. 17A)

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Step-by-Step Guide to Appealing Your Assessment

Step 1: Review Your Property Rates Demand Notice

When you receive your rates demand, carefully review:

• The rateable value assigned to your property
• The property particulars (address, size, description)
• The valuation reference date
• The effective date of the assessment

Action: Check the Valuation List online at the RVD's Property Information Online (PIO) website (www.rvdpi.gov.hk) or visit the RVD Enquiry Counter at 15th Floor, Cheung Sha Wan Government Offices.

Step 2: Gather Comparable Rental Evidence

To support your objection, collect evidence demonstrating that the rateable value is incorrect:

• Rental agreements: Actual lease agreements for similar units in the same or adjacent buildings signed within 12 months of the valuation reference date
• Market rental data: Evidence of market rents from property agents or online rental platforms
• Property condition evidence: Photographs, engineering reports, or inspection reports showing defects or conditions affecting value
• Comparable properties: Rateable values of similar properties in your building or locality

Key Point: Objective evidence such as copies of lease agreements, transaction records, photos, or engineering reports must be provided. Merely stating that the assessment "feels too high" is not persuasive.

Step 3: Determine the Correct Form and Deadline

Identify which form applies to your situation:

Your Situation	Form to Use
Received annual rates demand (April each year) and disagree with new rateable value	Form R20A or e-R20A Deadline: March 17 - May 31
Received interim valuation notice (Form R6) for newly completed property or alterations	Form R23A or e-R23A Deadline: 28 days from notice

Step 4: Complete and Submit the Objection Form

Where to obtain forms:

• Download from the RVD website Forms Section (www.rvd.gov.hk/en/public_forms)
• Submit electronically using Form e-R20A or e-R23A through the "Electronic Submission of Forms" service on the RVD website (recommended)
• Collect paper forms from the RVD Enquiry Counter or Home Affairs Enquiry Centres

Information required on the form:

• Your name, contact details, and capacity (owner, occupier, or agent)
• Property address and assessment number
• Current rateable value being challenged
• Proposed rateable value you believe is correct
• Grounds for objection with specific details
• Supporting evidence and documentation

Submission methods:

• Electronic submission via RVD website (fastest and recommended)
• Personal delivery to RVD Enquiry Counter
• By post to: Rating and Valuation Department, 15/F Cheung Sha Wan Government Offices, 303 Cheung Sha Wan Road, Kowloon, Hong Kong

Step 5: Continue Paying Rates

Important: Rates and Government rent must continue to be paid as demanded based on the original rateable value during the objection and appeal process. Late payments will be subject to surcharges.

If your rateable value is subsequently reduced, adjustments will be made in future demands, and you will receive a refund for any overpayment.

Step 6: Await the Commissioner's Decision

After submitting your objection:

Objection Type	Decision Timeline
Form R20A (Annual Revaluation)	Before December 1 of the same year
Form R23A (Interim Valuation)	Within 6 months after the expiry of the 28-day objection period

You will receive a Notice of Decision (Form R22A) which will either:

• Confirm the original rateable value, or
• Provide a revised rateable value (which may be higher, lower, or the same), or
• Confirm whether the property is liable for assessment

Step 7: Consider Appeal to Lands Tribunal (If Necessary)

If you are not satisfied with the Commissioner's decision, you have 28 days from the date of service of the Notice of Decision to file an appeal with the Lands Tribunal.

Appeal procedure:

1. Complete Form 19 (Notice of Appeal)
2. Attach a copy of the Commissioner's Notice of Decision
3. File the appeal with the Registrar of the Lands Tribunal
4. Pay the required filing fee
5. Serve a copy of the appeal on the Commissioner within the same 28-day period
6. Comply with Lands Tribunal Rules (Cap. 17A) and any directions from the Tribunal

Note: The Lands Tribunal has the same power to grant remedies as the Court of First Instance of the High Court, and there is no limit on the amount in dispute. The Tribunal's judgment on valuation matters is final, though further appeals on points of law can be made to the Court of Appeal.

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Timeline Overview: The Complete Appeals Process

Stage	Timeframe	Action Required
Valuation List Published	Mid-March (annually)	Review new rateable values online or at RVD offices
Objection Period (Annual)	March 17 - May 31	Submit Form R20A/e-R20A if objecting to annual revaluation
New Rates Effective	April 1	Continue paying rates based on new rateable value
Commissioner's Decision (Annual)	Before December 1	Receive Notice of Decision (Form R22A)
Interim Valuation Notice	As issued by RVD	28 days to submit Form R23A/e-R23A from date of notice
Commissioner's Decision (Interim)	Within 6 months	Receive Notice of Decision (Form R22A)
Lands Tribunal Appeal	Within 28 days of Notice of Decision	File Form 19 with Lands Tribunal and serve copy on Commissioner
Tribunal Hearing	Varies (scheduled by Tribunal)	Present evidence and arguments; Tribunal issues judgment
Further Appeal (Optional)	Subject to leave	Appeal to Court of Appeal on points of law only

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Documentation and Evidence Requirements

Essential Documents for Objection to Commissioner

• Completed objection form: Form R20A/e-R20A or R23A/e-R23A as applicable
• Property ownership or occupancy proof: Title deed, tenancy agreement, or rates demand
• Comparable rental evidence: Recent tenancy agreements for similar properties (ideally within 12 months of valuation reference date)
• Property condition documentation: Photos showing defects, wear and tear, or factors affecting value
• Professional reports (if applicable): Engineering reports, surveyor's reports, or valuation reports
• Market data: Evidence of rental levels in your area from property agents or online platforms

Additional Documents for Lands Tribunal Appeal

• Notice of Appeal (Form 19): Properly completed with all required information
• Commissioner's Notice of Decision: Original copy of Form R22A
• All previous correspondence: Copies of your original objection and RVD's responses
• Expert valuation report (recommended): Professional valuation from a qualified surveyor
• Detailed comparable evidence: Comprehensive rental comparables with analysis
• Witness statements (if applicable): From property agents, valuers, or other relevant parties
• Proof of service: Evidence that you served the appeal on the Commissioner

What Makes Strong Evidence?

The RVD and Lands Tribunal give weight to:

1. Actual rental transactions: Genuine arm's length rental agreements signed near the valuation reference date
2. Multiple comparables: Several similar properties rather than a single example
3. Relevant comparables: Properties similar in size, age, condition, location, and facilities
4. Recent transactions: Rentals agreed within 6-12 months of the valuation reference date
5. Professional opinions: Reports from qualified surveyors or valuers (particularly for Tribunal appeals)
6. Objective documentation: Photos, reports, and other tangible evidence rather than subjective opinions

Weak evidence to avoid:

• Subjective feelings that the assessment is "too high"
• Your personal financial circumstances (not relevant to market rental value)
• Single or outdated rental comparables
• Properties that are not genuinely comparable
• Restrictions on your property (e.g., Home Ownership Scheme restrictions are not considered)

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Practical Examples

Example 1: Successful Annual Revaluation Objection

Scenario: Mr. Chan owns a 600 sq ft apartment in Kowloon. The 2025-26 Valuation List shows a new rateable value of $30,000 per month, increased from $26,000. He believes this is excessive.

Action taken:

1. In April 2025, Mr. Chan researches rental values and finds that three similar apartments in his building were let between September and November 2024 (around the October 1, 2024 valuation reference date) for $27,000-$28,000 per month
2. He obtains copies of two tenancy agreements from neighbors as evidence
3. He submits Form e-R20A online by May 15, 2025, proposing a rateable value of $27,500
4. He continues paying rates based on the $30,000 rateable value
5. In November 2025, he receives a Notice of Decision reducing the rateable value to $28,000
6. He receives an adjustment and partial refund in his next rates demand

Outcome: Successful reduction of $2,000 per month in rateable value, resulting in annual rates savings of approximately $1,200 (at 5% rate).

Example 2: Interim Valuation Objection

Scenario: Ms. Lee receives an interim valuation notice (Form R6) for her newly completed retail shop in Tsim Sha Tsui with a proposed rateable value of $80,000 per month.

Action taken:

1. Ms. Lee immediately researches comparable rental evidence for similar shops in the same area
2. She finds that her shop has structural defects (water seepage) that affect its rental potential
3. Within 20 days of receiving the notice, she submits Form e-R23A with:
   • Photos documenting the water seepage problem
   • An engineering report confirming the defect
   • Three tenancy agreements for comparable shops let at $70,000-$75,000
4. She proposes a rateable value of $72,000 given the defects
5. Five months later, the Commissioner issues a decision setting the rateable value at $74,000

Outcome: Reduction of $6,000 per month in rateable value, saving $3,600 annually in rates.

Example 3: Lands Tribunal Appeal

Scenario: A property management company receives the Commissioner's decision maintaining the rateable value of a commercial building at $500,000 per month. The company believes this significantly overstates the market rental value.

Action taken:

1. Within 28 days of receiving the Notice of Decision, the company files Form 19 with the Lands Tribunal
2. They pay the tribunal filing fee and serve a copy on the Commissioner
3. They engage a professional surveyor to prepare a detailed valuation report
4. The surveyor's report includes analysis of 15 comparable transactions and proposes a rateable value of $450,000
5. The matter proceeds to a hearing where both parties present expert evidence
6. The Tribunal issues a judgment setting the rateable value at $470,000

Outcome: Reduction of $30,000 per month, saving $18,000 annually in rates (at 5% rate). However, the company also incurred professional fees for the surveyor and legal representation.

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Common Mistakes to Avoid

• Missing deadlines: The most common error. The Commissioner has no discretion to accept late objections.
• Using the wrong form: Using Form R20A when R23A is required (or vice versa) will result in rejection.
• Insufficient evidence: Submitting objections without proper comparable rental evidence or documentation.
• Stopping rate payments: Failing to continue paying rates during the appeal process leads to surcharges.
• Irrelevant arguments: Citing personal financial hardship or subjective opinions rather than objective market evidence.
• Ignoring the valuation reference date: Using rental evidence from dates too far removed from the official valuation reference date.
• Not serving appeal on Commissioner: When appealing to Lands Tribunal, failing to serve a copy on the Commissioner within the deadline.
• Comparing non-comparable properties: Using properties that differ significantly in size, location, or quality.

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Understanding Outcomes and Success Rates

While specific success rate statistics for property rates appeals are not publicly available from the RVD or Lands Tribunal, understanding the factors that influence outcomes is important:

Factors Influencing Success

• Quality of evidence: Strong, recent, and relevant comparable rental evidence significantly increases success prospects
• Professional representation: Engaging qualified surveyors or legal professionals, particularly for Lands Tribunal appeals
• Magnitude of discrepancy: Larger discrepancies between assessed and actual market values are more likely to result in adjustments
• Property type: Standard residential properties with abundant rental comparables may be easier to challenge than unique or specialized properties
• Market conditions: Appeals following significant market downturns may have higher success rates

Possible Outcomes

Outcome	What It Means
Value Reduced	Your objection/appeal is successful. The rateable value is lowered, and you receive adjustments/refunds in future demands.
Value Confirmed	The Commissioner/Tribunal finds the original assessment correct. The rateable value remains unchanged.
Value Increased	Rare, but possible if the review reveals the property was undervalued. You may face higher rates going forward.
Partial Reduction	The rateable value is reduced, but not to the level you proposed. A compromise position.

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Legal Framework and Further Appeals

Rating Ordinance (Cap. 116)

The Rating Ordinance is the primary legislation governing property rates in Hong Kong. Key provisions include:

• Definition of "tenement" for rating purposes
• Basis for calculating rateable values
• Procedures for objections and appeals
• Rights and obligations of owners and occupiers
• Exemptions from rates

The full text is available at the Hong Kong e-Legislation website: www.elegislation.gov.hk/hk/cap116

Lands Tribunal Ordinance (Cap. 17) and Rules (Cap. 17A)

These govern the procedures and jurisdiction of the Lands Tribunal, including appeals from the Commissioner of Rating and Valuation.

Appeals Beyond the Lands Tribunal

The Lands Tribunal's judgment on valuation matters is final on factual issues. However, further appeals are possible on points of law only:

• Court of Appeal: Any party may appeal to the Court of Appeal on grounds that the Tribunal's decision is erroneous in point of law
• Court of Final Appeal: With leave, further appeals on legal points may reach Hong Kong's highest court

Important: Appeals on purely factual matters (e.g., whether the valuation was correct based on the evidence) cannot proceed beyond the Lands Tribunal.

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Resources and Contact Information

Rating and Valuation Department (RVD)

Address: 15/F Cheung Sha Wan Government Offices, 303 Cheung Sha Wan Road, Kowloon, Hong Kong

24-hour Hotline: 2152 0111 (handled by 1823 call center)

Website: www.rvd.gov.hk

Property Information Online: www.rvdpi.gov.hk

Forms Section: www.rvd.gov.hk/en/public_forms

Lands Tribunal

Address: Ground Floor, High Court Building, 38 Queensway, Hong Kong

Telephone: 2825 4643

Website: www.judiciary.hk/en/court_services_facilities/lands.html

Useful Publications

• "Your Rates and Government Rent" booklet: Available at www.rvd.gov.hk/doc/en/ratesandrent.pdf
• "Property Rates in Hong Kong" (3rd Edition): Comprehensive guide available from RVD
• Lands Tribunal Forms and Guidance Notes: Available at the Judiciary website

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Professional Assistance

While objections to the Commissioner can often be handled without professional assistance, you may wish to engage professionals in the following situations:

• Complex properties: Commercial properties, industrial buildings, or unique properties requiring specialist valuation knowledge
• High-value properties: Where the potential rates savings justify professional fees
• Lands Tribunal appeals: Professional representation is strongly recommended for tribunal proceedings
• Lack of rental evidence: When it's difficult to find comparable rental transactions
• Time constraints: If you're unable to gather evidence and prepare the objection yourself

Professional advisors who can assist:

• Chartered surveyors specializing in property valuation
• Property tax consultants
• Solicitors or barristers with experience in rating and valuation law
• Property agents with local market knowledge

Disclaimer: This guide provides general information about the Hong Kong property rates appeal process and should not be considered legal or professional advice. The information is current as of December 2025. For specific advice regarding your property rates assessment, consult the Rating and Valuation Department, the Lands Tribunal, or seek professional assistance from qualified surveyors or legal advisors. Always refer to the official Rating Ordinance (Cap. 116) and current RVD guidelines for authoritative information.