Exception Register — Municipal Property Tax
Why property-tax exceptions need their own register
Municipal property tax is governed by Law No. 1319 and implemented through tax values, building/land characteristics and municipal records that can change across years. In a transaction file, problems are often blurred into a single note such as “tax issue.” A useful exception register separates the actual discrepancy: wrong taxpayer, wrong property identifier, unexpected tax value, missing declaration/update, unpaid instalment, exemption claim, inconsistent building classification or a difference between municipal information and the transaction file. Each item then receives a responsible owner and a documentary closure condition.
Start from the exact property and tax year
Record municipality, neighbourhood, block/parcel and—where the municipal system uses it—the unit/account reference. State the tax year and whether the issue relates to building tax, land tax or another municipal charge. A receipt from a different year or another unit in the same building cannot close the exception. The current taxpayer and ownership period should also be identified because acquisition and disposal dates affect which records belong to which owner. Avoid mixing property tax with unrelated environmental cleaning tax, utility debt or site aidat.
Identify the official value being disputed
The emlak vergisi value is not the same thing as an asking price, appraisal, bank valuation or market value. For transaction review, compare the value shown by the relevant official municipal/transaction source with the property identifiers and year. TKGM’s sale guidance indicates that the emlak vergisi value is transmitted electronically in the sale process. If a file contains a manually typed value that conflicts with the current official record, open an exception and obtain the current official basis rather than choosing the figure that best suits the transaction.
Use current statutory updates carefully
GİB publishes communiqués that affect property-tax calculations and construction-cost inputs. The 89 Series communiqué published at the end of 2025 addresses the 2026 tax-value framework, while the 90 Series communiqué of 6 August 2026 publishes normal construction-cost figures relevant to 2027. These are not interchangeable. An exception should state which year and rule is being applied. Do not use a 2027 construction-cost table to “correct” a 2026 municipal assessment or assume that a national communiqué replaces the municipality’s individual account record.
Separate payment status from value status
A correct tax value does not prove that all instalments were paid, and a payment receipt does not prove the underlying value or property match is correct. If the issue is unpaid tax, record the period, amount shown by the official account and payment evidence. If the issue is valuation/classification, record the source and correction route. Keep these as separate exceptions so a bank receipt cannot accidentally close a data-quality problem and a corrected value cannot be mistaken for proof of payment.
Handle exemption or special-status claims with evidence
Do not accept a seller’s statement that “no tax is due” without identifying the legal/administrative basis. Exemptions or reduced treatment can depend on facts about the owner and property and should be supported by the competent official record or documentation applicable to the relevant year. The exception should say whether the claim affects liability, rate, value or only a specific period. If the municipality has not accepted the claim, record it as unresolved rather than converting it into a completed item.
Link the exception to transaction decisions without inventing legal effects
A property-tax discrepancy may justify holding a contractual amount or delaying an internal approval if the parties agreed that current municipal liabilities must be cleared. But do not state that every property-tax debt automatically makes title transfer legally impossible unless the applicable official procedure says so. The register should distinguish statutory requirements from contractual risk controls. For sale pricing, also remember that TKGM guidance applies a declared transaction-value floor linked to the emlak vergisi value; verify the current figure rather than using an old certificate.
Close with the competent evidence
A good closure packet may include an updated municipal account, corrected property/taxpayer record, official tax-value document, payment receipt linked to the right period, or formal confirmation relevant to an exemption. Record date, reviewer and why the evidence answers the exact discrepancy. Preserve the original conflicting document as superseded evidence. If the municipality issues a new assessment or the law changes for a later year, create a new item rather than rewriting history.
Quality standard
The register should make it possible to answer: which property, which year, which taxpayer, what type of tax, what value or payment is disputed, what official source controls, who owns the fix, what transaction action is affected and what exact evidence will close it. This keeps municipal property-tax review factual and prevents generic tax language from contaminating unrelated records.