Georgia's 299(c) Rule: How One Appeal Can Freeze Your Property Value for 3 Years

Most homeowners think of a property tax appeal as a one-year fix — you fight your assessed value, get a reduction, and have to do it all over again next year. In most states, that's exactly how it works.

Georgia is different.

Thanks to a powerful but little-known provision in Georgia tax law — O.C.G.A. § 48-5-299(c) — a single successful property tax appeal can freeze your assessed value for up to 3 full years. That means one appeal today could protect you from rising assessments through 2028.

This is, hands down, the single biggest advantage Georgia homeowners have when it comes to property taxes. Here's exactly how it works.

What Is the 299(c) Rule?

Section 299(c) of the Official Code of Georgia Annotated (O.C.G.A. § 48-5-299) establishes that when a property owner successfully appeals their assessed value through the Board of Equalization (or a higher authority like Superior Court or arbitration), the resulting value becomes the base value for the property.

This base value is then locked in for the appeal year plus the following two tax years — a total of up to 3 years. During this freeze period, the county Board of Tax Assessors cannot increase your property's assessed value.

How the 3-Year Freeze Works in Practice

Let's walk through a real-world example to show why this matters so much.

In this example, the homeowner saved nearly $4,000 over three years from a single appeal. Without the 299(c) freeze, they would have only saved $960 in the first year before the county raised the value again.

What Triggers the Freeze?

The 299(c) value freeze is triggered when your appeal is resolved at any of these levels:

• Board of Equalization (BOE): The most common resolution point. If the BOE reduces your value, the freeze kicks in.
• Hearing Officer: Some counties use hearing officers instead of or in addition to the BOE.
• Arbitration: For residential properties valued under $750,000, you can opt for binding arbitration.
• Superior Court: If you appeal the BOE decision to court and win, the freeze applies.

Important: The freeze applies when the appeal goes beyond the assessor level. Informal reductions agreed to directly with the assessor's office may not trigger the 299(c) protection — which is another reason to ensure your appeal is formally processed through the Board of Equalization.

What Can Break the Freeze?

The freeze isn't completely unconditional. There are specific circumstances where the county can adjust your value during the freeze period:

• Physical improvements: If you add an addition, build a pool, do a major renovation, or make other significant improvements, the county can increase the value to reflect the improvement — but only for the value of the improvement itself.
• Property damage or destruction: If the property is damaged (fire, storm, etc.), the value may be adjusted downward.
• Change in property use or zoning: Rezoning or conversion from residential to commercial use can trigger a reassessment.

What does NOT break the freeze:

• General market appreciation
• Neighboring properties selling for more
• County-wide reassessment initiatives
• Changes in millage rates (those affect your tax bill but not your assessed value)

Why This Matters More Than You Think

In rapidly appreciating markets like metro Atlanta, Gwinnett County, and other parts of Georgia, property values have been climbing 5–10% per year. Without the 299(c) freeze, that means your assessed value — and your tax bill — goes up right along with it.

With the freeze, you're effectively insulated from those increases for three years. Think of it as a property tax shield:

• Year 1: You save the direct difference from the appeal
• Year 2: You save the Year 1 amount PLUS whatever the county would have raised your value
• Year 3: Savings compound further as the gap between your frozen value and market trends widens

The longer the market appreciates during your freeze period, the more you save. In a hot market, the 299(c) freeze can easily double or triple the value of your original appeal.

Georgia vs. Other States

To put this in perspective, here's how Georgia's appeal protections compare:

• Texas: No value freeze. You must protest every year. Assessments can jump significantly each year.
• Florida: No freeze from appeals. The Save Our Homes cap limits increases to 3% for homesteaded properties, but that applies regardless of appeals.
• California: Prop 13 limits increases to 2% per year, but only from the purchase price base — not related to appeals.
• Georgia: 3-year value freeze after any successful appeal. Best appeal protection in the country.

How to Maximize the 299(c) Freeze

1. Appeal aggressively. The lower you get your value in the appeal, the more the freeze is worth. Every dollar counts times three.
2. Ensure your appeal goes through the BOE. Informal settlements with the assessor may not trigger the freeze. Make sure the appeal is formally resolved.
3. Time your improvements. If possible, file your appeal before starting major renovations.
4. Use a professional. An experienced representative can often achieve a larger reduction than a homeowner alone — and with the 3-year multiplier, that expertise pays for itself many times over.
5. Plan your next appeal. Mark your calendar for Year 3 of the freeze. When it expires, file a new appeal immediately if values have risen.

Frequently Asked Questions

Does the freeze apply to the tax bill or the assessed value?

The freeze applies to the assessed value. Your actual tax bill could still change if the millage rate changes. However, millage rate changes are typically small — the big driver of tax increases is assessed value, which the freeze locks in.

What happens when the freeze expires?

After the 3-year freeze period, the county can reassess your property at current market value. This is why it's important to be prepared to file a new appeal when the freeze ends if market values have risen significantly.

Can I file a new appeal during the freeze?

Generally, there's no reason to appeal during the freeze since the county can't raise your value. However, if your property has lost value (market downturn, damage, etc.), you could potentially appeal for an even lower value.

Do I have to do anything special to get the freeze?

No. The 299(c) freeze is automatic. When your appeal is resolved through the Board of Equalization (or higher authority) and results in a reduced value, the freeze is applied by operation of law. You don't need to file additional paperwork.

Related Articles:
Complete Guide to Georgia Property Tax Appeals in 2026
Property Tax Appeals by County: Fulton, DeKalb, Gwinnett, Cobb & More