About tax valuation of leasehold plots for residential/holiday property

When calculating wealth tax, the decisive factor is which assets with a financial value you own at the end of the year. As the lessee (rights holder) of a plot of land, you do not own the plot as such - you rent it from a landowner in return for payment.

However, the Ground Lease Act gives all lessees of residential and holiday plots the right to have their leasehold agreement extended perpetually. This will have consequences as regards who will be liable for wealth tax on the value of the plot.

As lessee (the party that is leasing - rights holder)

You do not own the plot as such. Because the Ground Lease Act gives all lessees of residential and holiday plots a perpetual right to have their leasehold agreement extended, the usufruct (the leasehold right) is deemed to be equivalent to actual ownership of the plot for the purposes of wealth tax. In turn, this means that you as lessee will be subject to wealth tax on the value of the plot.

You will also be entitled to a deduction for debt for the capitalised obligation to pay ground rent. (I.e. a present value of the payment obligation you have taken on under the leasehold agreement will be calculated. This value will then be considered a debt, which in turn will reduce the basis for your wealth).   

As lessor (landowner)

You will not be liable for wealth tax on the value of the leased land. Lessors are only liable for wealth tax for the capitalised value of receiving ground rent.