Supreme Court rules time passage alone does not justify inheritance tax reassessment

The Supreme Court ruled that the mere passage of time cannot automatically exclude general price fluctuations when determining whether special circumstances exist for inheritance tax assessments. Tax authorities must prove the absence of such circumstances between the valuation date and the actual transaction date.

The court reasoned that excluding general market movements would contradict the legislative intent of calculating property values based on objective exchange rates.

The ruling stemmed from a case where an individual inherited land on October 13, 2019, and reported it using the officially assessed individual land price on April 30, 2020. The heir later sold portions of the land on September 24, 2020, and January 15, 2021, but the local tax office reassessed the inheritance value on August 8, 2022, based on these subsequent sales prices.

Judges found that the tax office failed to provide sufficient evidence showing no special price-changing events occurred between the inheritance date and the sales contracts, upholding the lower tribunal's view that using later sales figures as fair market value for the earlier inheritance was unlawful.

The court emphasized that authorities must comprehensively consider factors including changes in legal or physical status, regulatory environments, and cumulative shifts in publicly announced land prices. If significant value changes are recognized during the interim period, the later transaction price cannot serve as the standard market value for the earlier assessment.