Basic Tax Content

Administrative Policy

4 April 2011 Interpretation Case No. 113955

a university which is the registered and beneficial owner of three contiguous parcels of land (A, B and C) reconfigures its ownership so that it is the owner of parcel AB consisting of all of (former) parcels A and B plus a portion of (former) parcel C, and parcel C1 representing the balance. Such reconfiguration would cause parcels A, B and C to cease to exist for ETA purposes. However, the basic tax content of parcel AB will consist of that of former parcels A and B plus that portion of the basic tax content of parcel C (calculated immediately before that parcel ceased to exist) that can fairly and reasonably attributed to the area in parcel C that became part of parcel AB.