What is the 299c Freeze?
Georgia's "299c freeze," shorthand for Georgia Statute 48-5-299(c), is a powerful property tax protection mechanism that can “lock” or “freeze” your property's assessed value for three years following a successful property tax appeal.
So, when a property owner successfully appeals their tax assessment and receives a reduction (or even maintains the same value) at the Board of Equalization (BOE), hearing officer, arbitrator, or Superior Court level, the county tax assessor cannot increase that property's assessed value for the next two successive years.
This statute effectively creates a three-year freeze on your property tax assessment.
The History Behind the Freeze
Georgia lawmakers enacted the 299c provision in 2016 to protect property owners who try to appeal their assessments. Georgia’s legislator recognized that without this protection, property owners who successfully challenged inflated assessments could be back in the appeals process each year, creating an unfair burden on taxpayers and local counties' resources.
Fluctuating property values and rising tax assessments across Georgia, particularly in Atlanta, have made the property tax code provision increasingly crucial.
Scope of the Freeze and Example Calculation
Georgia law states that a property’s assessed value is 40% of its fair market value. The 299c freeze applies to the assessed value. Once established, the locked value typically remains unchanged for the appeal year and the two subsequent tax years, resulting in three years of stability. Below is an example calculation:
Property’s Initial Pre-Appeal Value:
Fair market value: $500,000
Assessed value (pre appeal): $500,000 x (0.40) = $200,000
2025 Successful Appeal:
Let’s say a successful appeal decreases the market value by $20,000
New fair market value: $480,000
New assessed value (after reduction): ($480,000 x 0.40) = $192,000
Tax Calculation (hypothetical): To illustrate, let's assume a millage rate of 30 mills (or 0.030). Note that the millage rate is not frozen, only the assessed value.
2025, 2026, and 2027 property taxes: $192,000 (appealed assessed value) * 0.030 (millage rate) = $5,760
*Assuming the millage rates don’t change each year, which is rare.
As shown in the example, the three-year property tax freeze provides a significant financial benefit, essentially tripling the savings from a successful appeal. It enables property owners to plan their future tax expenses more confidently.
Primary Benefits of Freezing Your Assessed Value
The property tax provision establishing this freeze allows homeowners and commercial investors a forward-looking approach to managing property taxes. The 299c freeze enables them to:
Utilize appeals for immediate tax relief and as a safeguard against future market value increases.
Shift from reacting to annual assessments to continuous tax optimization.
Gain greater certainty in budgeting and financial planning by locking in a property value.
How to Obtain the 299c Freeze
For homeowners and commercial property owners, the process for securing a 299c freeze involves several critical steps:
File a timely appeal: You must file your property tax appeal within 45 days of receiving your assessment notice or notice of value
Proceed beyond initial negotiations: Simply filing an appeal isn't enough — you must either:
Reach a written settlement with the tax assessor's office
Proceed to a formal BOE hearing and obtain a decision
Attend your hearing: You or an authorized representative (like Ownwell) must attend the BOE hearing either physically or virtually and present evidence supporting your valuation.
Ensure proper documentation: The freeze must be noted explicitly in the settlement agreement or BOE decision.
Commercial property appeals typically involve more sophisticated valuation methodologies, including income capitalization approaches and detailed market analyses. However, the fundamental process for securing the 299c freeze remains the same.
Exceptions That Can Break the Freeze
While the 299c freeze provides valuable stability, it is not immutable and can be altered under specific circumstances, which the taxpayer largely controls.
1. Substantial Additions or Improvements
The tax assessor's office retains the right to adjust the frozen value if significant additions, deletions, or improvements to the property materially affect its fair market value. This ensures that major enhancements to a property get reflected in its taxable value.
2. Selling the Property
The freeze automatically terminates upon the sale of the property. A new owner will typically face a reassessment based on the latest transaction value, which, by state law, may not exceed the sale price for one year following a bona fide, arm’s length sale.
3. Voluntarily Appealing a Locked Value
A critical exception is the property owner's ability to proactively appeal an already locked value.
This action effectively "breaks the lock.” If the subsequent appeal achieves a lower value, a new three-year lock is established at this new, reduced value. However, your assessed value could increase, and you’d lose the three-year lock until the following year. Thus, we only recommend appealing a frozen value during significant market downturns.
4. Filing a Return at a Different Valuation
If the taxpayer files a property tax return at a different valuation during the two successive years following the freeze, the freeze may become invalid.
Example: You successfully appealed your property tax assessment in 2025, and the county froze your property value at $300,000 for 2026 and 2027.
However, in 2026, you file a property tax return stating your property is worth $280,000. By doing this, you could lose the $300,000 frozen value for the remainder of the freeze period.
Thus, it’s essential to correctly report your property value to maintain the freeze.
Should You Forgo Your 299c Freeze and Reappeal?
Determining whether to relinquish a 299c property tax freeze and risk reappealing hinges on carefully analyzing current market values versus the frozen assessment to maximize potential tax savings.
The Core Dilemma: Weighing Stability vs. Potential Savings
The 299c freeze provides valuable predictability and protection against rising assessed values, especially in dynamic markets, by locking in an assessed value for three years.
However, if market values decline significantly below the current frozen assessed value, maintaining the freeze means paying taxes on an inflated valuation.
When to Maintain Your 299c Freeze
Keep your frozen assessed value if:
Property values are rising: In an appreciating market, your frozen assessment becomes increasingly valuable
Your freeze discount is substantial: If your frozen value is ~20% or more below current market assessments
You plan to hold the property: Long-term owners benefit most from the freeze
Market indicators suggest continued growth: Current real estate market forecasts show continued appreciation and growth
When to Consider Giving Up Your Freeze
The core principle is to appeal if a property's current fair market value is demonstrably lower than the fair market value equivalent of its frozen assessed value.
So, consider appealing again (and potentially losing your freeze) if:
Significant market downturn: Your property's actual value has dropped substantially below your frozen assessment
The math supports it: Calculate the potential savings:
Current frozen assessed value × 40% × millage rate = Current tax bill
Potential new assessed value × 40% × millage rate = Potential tax bill
If the difference exceeds the risk of future increases, consider appealing
In general, there’s no single, fixed percentage for a "tipping point" that universally applies, as the decision to appeal depends on the property’s:
Specific frozen value
The current market value
The applicable millage rate
Focus On Your Current Market Value Vs. Frozen Assessed Value
The emphasis on comparing the current market value to the frozen assessed value means the "downturn" that justifies an appeal is not simply a general market percentage drop, but specifically how much your property's current fair market value has fallen relative to its frozen fair market value equivalent.
Even if the overall market is only slightly down (e.g., 2-3% as some forecasts suggest for Atlanta residential), if a property was frozen at a peak value during a previous assessment cycle, a seemingly minor market correction could still make an appeal worthwhile for that specific property.
Illustrative Scenario for Appealing a Frozen Commercial Value
The following table provides an example of typical commercial properties to illustrate the financial implications of appealing a frozen value under various market decline scenarios.
Scenario | Initial Frozen Fair Market Value Equivalent | Declining Current Market Value | Initial Frozen Assessed Value (40% of FMV) | Corresponding Declining Assessed Value | Annual Tax Savings Compared to Frozen Value (25 mills) | Cumulative 3-Year Savings/Loss (new freeze established) |
|---|---|---|---|---|---|---|
Current Freeze | $2,500,000 | $2,500,000 | $1,000,000 | $1,000,000 | $0 | $0 |
5% Decline | $2,500,000 | $2,375,000 | $1,000,000 | $950,000 | $1,250 ($1M - $950K) * 0.025 | $3,750 |
10% Decline | $2,500,000 | $2,250,000 | $1,000,000 | $900,000 | $2,500 ($1M - $900K) * 0.025 | $7,500 |
20% Decline | $2,500,000 | $2,000,000 | $1,000,000 | $800,000 | $5,000 ($1M - $800K) * 0.025 | $15,000 |
This table demonstrates that even moderate declines in fair market value can lead to tangible annual and cumulative tax savings, making it financially advantageous to appeal a frozen value under the right conditions.
Cost Benefits of Professional Assistance
The Georgia property tax appeal process is complicated; it involves:
Specialized rules
Tax laws and billing regulations
Different approaches to valuation
Negotiations with government officials
Presenting evidence at public hearings
Tax assessor offices often possess overwhelming advantages over individual property owners due to their specialized knowledge and resources.
The Georgia 299c property tax freeze remains a powerful and essential tool for achieving property tax stability and predictability in Georgia. It gives homeowners and property owners a reason to appeal their assessed values.
That said, it comes at a cost. If you have a poor appeal case, you could only get a minor reduction for the next three years, or worse, your market and assessed values can actually increase!
Using a Professional Service
To secure the most considerable property tax reduction for the upcoming three years, consider leveraging a professional property tax appeal service such as Ownwell. We can assist in building the strongest possible appeal case.
Our local property tax consultants are well-versed in each county’s intricacies and are familiar with the appraisers, boards, and hearing officers.
Our local expertise and proprietary software generate an average of $1,102 in savings per homeowner. So, ensure you maximize your savings potential with Ownwell's expert guidance. See how much you can reduce your assessed value and freeze it for the next three years!
