New Property Tax Rules – First Interpretations Have Arrived

At the beginning of 2025, changes to the property tax regulations came into effect. The amendment introduced, among other things, new definitions of buildings and structures, along with a detailed list of facilities classified as structures for tax purposes. The reform aimed to simplify and clarify the regulations. But did it succeed? The first interpretations from tax authorities suggest the situation is far from straightforward.

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🧱 Mobile containers = structure?

A construction company asked whether the mobile containers it uses on building sites — temporarily placed on concrete blocks and moved between locations — are subject to property tax.

Despite the lack of foundations or permanent attachment to the ground, the city mayor ruled that such containers qualify as structures. His reasoning: they are stable and “assembled,” which, under the new rules, is enough to consider them the result of construction work. The company disagrees with this interpretation and is likely to challenge it in court.

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🚗 Garages in service buildings – higher tax rate

Another interpretation concerned garages located in commercial-service buildings but used by residents of the building. The applicant argued that since the garages serve residents, they should qualify for the preferential residential tax rate.

The tax authority rejected this position. It emphasized that only garages in buildings officially classified as residential are eligible for the lower rate. In service buildings, even if garages are used by residents, the higher tax rate applies.

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Uncertainty instead of simplification?

Although the goal of the amendment was to eliminate interpretative disputes, the first rulings from tax authorities show that even more complications may arise. In some cases — such as the mobile containers — tax officials apply an expansive interpretation, which goes against the principle of acting in favor of the taxpayer. That leaves only one option: a legal challenge.