GEORGIA · 299(c) VALUE FREEZE

Georgia's 299(c) Value Freeze: Three Years From One Appeal

A successful Georgia appeal does more than cut one year's assessment. Handled correctly, it locks the value for the appeal year and the two that follow — which is where most of the money actually is.

How GA Appeals Work

3 years

Appeal year plus two successive years

48-5-299(c)

The governing code section

Value only

Millage rates can still change

Owners evaluating whether a Georgia appeal is worth the effort almost always run the wrong calculation. They compare the cost of appealing against one year of tax savings, decide the margin is thin, and let the 45 days run. The number they should be running is closer to three times larger, because Georgia law protects a value won on appeal for the two tax years that follow it.

O.C.G.A. § 48-5-299(c) is the most valuable and least understood feature of the Georgia system. It is also conditional in ways that matter: how your appeal resolves can determine whether you get the freeze at all, and several ordinary business events can end it early. This guide covers what triggers it, what it covers, what cancels it, and how it should change the way you evaluate an appeal. EPTA represents commercial owners across Georgia, alongside Michigan, Indiana, Ohio, Pennsylvania, and Wisconsin.

Why the Freeze Exists

Without something like 299(c), an assessment appeal would be a treadmill. An owner wins a reduction in year one; the assessors restore the value in year two; the owner appeals again. The taxpayer bears the cost of the process every year and the county bears none of the consequence of having been wrong.

The freeze breaks that cycle by giving a value established on appeal a defined shelf life. For commercial owners in appreciating submarkets the effect compounds: while comparable properties are being reassessed upward each year, a frozen parcel holds its value through the term. In a genuinely rising market, years two and three of a freeze are frequently worth more than the original reduction was.

HOW THE FREEZE WORKS

From Appeal to Protected Value

The freeze is not automatic in every scenario. How the matter concludes, and what happens to the property afterward, both affect whether the protection holds.

File a Real Appeal Inside the 45 Days

The freeze flows from the appeal process, so it starts with a timely appeal — filed within 45 days of the notice date under O.C.G.A. § 48-5-311. An owner who calls the assessor to complain and gets an informal adjustment has not started this process. Our Georgia deadline guide covers the filing window in detail.

Let the Value Be Established Through the Process

The protection attaches to a value determined by the board of assessors on the appeal, the Board of Equalization, a hearing officer, an arbitrator, or Superior Court. This is the step where owners give away the freeze without realizing it — by accepting an off-process adjustment that resolves the year but leaves the following two unprotected. When a county offers a number, ask how the resolution will be documented, not just what the number is.

Count the Term Correctly

The assessors generally may not increase the established value for the two successive tax years after the year at issue. Counting the appeal year itself, that is up to three years of protection. Diary the expiration date, because the year the freeze lapses is the year to be watching for a large correction — counties frequently move a long-frozen value substantially the moment they are able to.

Understand What Is Not Frozen

The freeze holds value, not taxes. Millage rates set by the county, the schools, and other levying authorities move independently, so a bill can rise during a freeze without the protection having failed. Understanding this distinction avoids a common and unnecessary alarm. Our guide to understanding your tax bill separates the two components.

Watch the Events That End It Early

A sale of the property, substantial improvements or additions, filing a return at a different value, or filing a new appeal can each terminate the freeze before the term runs. The improvement trigger is the one commercial owners hit most often: a major renovation or expansion mid-freeze changes what is being valued and can reopen it. If a capital project is planned during a freeze period, factor the lost protection into the project economics.

Decide Deliberately Before Appealing Again

Because a new appeal can end an active freeze, the reflex to appeal every year is counterproductive in Georgia. Appealing into a running freeze makes sense only when the market has moved enough that a materially lower value is achievable — enough to outweigh the remaining protected years you are giving up. That is a portfolio-level judgment, and it is worth making explicitly rather than by habit.

PROTECTING THE FREEZE

Georgia 299(c) Self-Check

The freeze is worth more than most owners realize and easier to lose than most owners expect. Run through these during the appeal and again each year it is running.

I filed a timely appeal rather than seeking an informal adjustment

I confirmed the resolution establishes value through the appeal process

I diaried the freeze term and the year it expires

I understand millage rates can still raise my bill during the freeze

I checked whether any planned capital project would end the freeze early

I know that filing a new appeal can terminate the protection I already hold

I valued the appeal on up to three years of savings, not one

299(c) FREEZE FAQ

What Georgia Owners Ask About the Freeze

Under O.C.G.A. § 48-5-299(c), when a property's value is established through the appeal process, the county board of tax assessors generally may not increase that value for the next two successive tax years. Counting the appeal year itself, that is up to three years of protection from a single appeal. The provision exists to stop assessors from simply reversing a taxpayer's win the following January, and it is the reason a Georgia appeal is often worth more than one year of savings suggests.

Often not, and this is the most consequential detail in the whole provision. The freeze attaches to a value established through the appeal process — by the board of assessors on an appeal, the Board of Equalization, a hearing officer, an arbitrator, or Superior Court. A purely informal adjustment made outside that process may leave you with this year's reduction and nothing protecting the next two. When a county offers an attractive number early, the right question is not only whether the number is good but whether accepting it that way carries the freeze.

No. The freeze holds the assessed value, not the tax bill. Millage rates are set separately by the county, the schools, and other levying authorities, and they can rise while your value is frozen. What the freeze guarantees is that the assessors cannot re-inflate the value underneath the rate. In a rising market that protection is substantial, because it holds your value flat while comparable properties around you are reassessed upward.

Several things. A sale of the property, substantial improvements or additions that change what is being valued, filing a return at a different value, and filing a new appeal can each end the protection before the term runs. The improvement trigger matters most for commercial owners: a major renovation or expansion during the freeze period can reopen the value. That is worth factoring into project timing when a freeze is in place and a capital plan is under consideration.

Usually not, and this surprises owners who are used to appealing annually. Filing a new appeal during the freeze period can end the protection you already hold. If the market has fallen far enough that a new, lower value is clearly achievable, a fresh appeal may still be right — but it is a decision to make deliberately, with the value of the remaining freeze years priced in. We track freeze terms across client portfolios for exactly this reason. Start with a free review before filing into an active freeze.

ONE APPEAL, UP TO THREE PROTECTED YEARS

Make Your Georgia Appeal Count for More Than One Year.

We'll evaluate your assessment, file inside the 45-day window, and resolve the matter in a way that establishes value through the appeal process so the freeze attaches.

Contingency representation across Michigan, Indiana, Ohio, Pennsylvania, Wisconsin, and Georgia. Beyond a modest filing retainer, no fee unless we reduce your taxes.

Low upfront cost. No obligation.

Resolving a Georgia property tax appeal in a way that secures the 299(c) value freeze