Pennsylvania Consolidated Statutes

53 Pa. Cons. Stat. § 8565 (2026)

Assessments and appeals for certain tax years.

✓ current as of May 2026

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§ 8565. Assessments and appeals for certain tax years.

(a) Legislative findings.--The General Assembly finds and declares as follows:

(1) Real estate tax assessment in a city has become increasingly at variance with principles of uniformity and sound assessment.

(2) The deficiencies under paragraph (1) have been determined to be remedied by a citywide reassessment, sometimes referred to as the "actual value initiative."

(3) The reassessment of all properties located in a city is likely to cause substantial shifts in tax liabilities among various neighborhoods and groups of taxpayers. These shifts are likely to increase substantially the tax burdens on residential properties, particularly those properties with low to medium values.

(4) As part of a reassessment, the governing body must make a major revision to the applicable tax rates in order to maintain tax revenues and fund any required tax increases. The governing body must take into account enactment of a homestead exclusion and perhaps other measures in order to alleviate an increased tax burden on lower value residential properties.

(5) The governing body cannot responsibly determine the applicable tax rates without knowing the value of the tax base to which the rates apply. Currently, a city's budget, including tax revenues, must be enacted by each June 30, but tax assessments are not finalized until the following September.

(6) Implementation by a city of an actual value initiative will be helped by requiring that assessed values be determined prior to adopting the city's budget and by the applicable assessment officials completing the task of determining the tax base in the city.

(7) The common level ratio for a city applicable to tax year 2012, certified by the State Tax Equalization Board and published at 42 Pa.B. 2152 (April 14, 2012), has been disputed and may be subject to further dispute. The common level ratio for tax year 2013 may have similar uncertainties. The ratios for both years are determined by a State Tax Equalization Board assessment tool new to the review of properties in a city.

(8) The common level ratio for a city applicable to tax year 2011, based on 2009 data and published at 40 Pa.B. 4069 (July 17, 2010), has not been disputed and is the same as the applicable established predetermined ratio.

(9) Special provisions are necessary in order to address the findings set forth in this subsection.

(b) Certification of values.--Notwithstanding any other provision of law:

(1) For tax year 2013, the assessment office shall certify assessed values at the assessed values certified for tax year 2011, adjusted for subsequent improvements, demolition and destruction. The assessed values certified for tax year 2013 under this paragraph shall apply to all taxes on or measured by assessed values levied by a city or a school district for tax year 2013 notwithstanding any contrary enactment of a city or a school district or any contrary certification by a city, city agency or school district.

(2) For tax years after tax year 2013, the assessment office shall certify market values at actual market value. In arriving at actual market value, the price at which any property may actually have been sold shall be considered but shall not be controlling. In arriving at the actual market value:

(i) All three of the following valuation methods shall be considered in conjunction with one another:

(A) Reproduction or replacement cost, as applicable, minus:

(I) depreciation; and

(II) all forms of obsolescence.

(B) Comparable sales.

(ii) The valuation process may employ systems, methodologies and technologies that meet nationally recognized assessment standards.

(c) Timing of certification.--Notwithstanding any other provision of law, for tax years after tax year 2013, the assessment office shall certify assessed values by March 31 of the preceding year.

(d) Application of established predetermined ratio.--Notwithstanding any other provision of law, in any assessment appeal under Act 1939-404 for tax year 2013, the board and any applicable court of competent jurisdiction shall apply the established predetermined ratio applicable to a city for tax year 2011.

(e) Conflicts.--If there is a conflict between a provision of Act 1939-404 and a provision of this section, the provision of this section shall apply.

Notes of Decisions

Cited in 7 cases (2 in the last 5 years), 2015–2025 · leading case: Starwood Airport Realty v. Sch. Dist. of Philadelphia, 115 A.3d 410 (Pa. Commw. Ct. 2015).

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Starwood Airport Realty v. Sch. Dist. of Philadelphia, 115 A.3d 410 (Pa. Commw. Ct. 2015). · cites it 2× “at 2 (citing 53 Pa.C.S. § 8565(b)(1).)) Thus, Starwood’s tax liability for the 2013 tax year increased back to the pre-appeal level.”

A. Collier v. City of Philadelphia, Bd. of Revision of Taxes (Pa. Commw. Ct. 2017). · cites it 2× “However, Section 8565(c) of the statute known as the Consolidated First Class County Assessment Law (Consolidated Assessment Law), 53 Pa. C.S. §8565(c), states that “[n]otwithstanding any other provision of law, for tax years after tax year 2013, the [OPA] shall certify assessed…”

Duffield House Assoc., L.P. v. City of Philadelphia ~ Appeal of: City of Philadelphia & S.D. of Philadelphia (Pa. Commw. Ct. 2021). · cites it 2× “In its Complaint, Duffield alleged that the City selectively reassessed only commercial properties at fair market value for Tax Year 2018, in violation of the Uniformity Clause and Section 8565(b)(2) and (c) of the Consolidated First Class County Assessment Law (Assessment Law),…”

In re: Appeal of M. Mishrikey ~ From a Decision of: The Bd. of Rev. of Taxes ~ Appeal of: M. Mishrikey (Pa. Commw. Ct. 2025). · cites it 2× “5 In the City, the “Actual Value Initiative,” 53 Pa.C.S. § 8565, requires property to be assessed at current fair market value as of the assessment date.”

The Robert Nicoletti Fam. Trust v. The SD of Philadelphia (Pa. Commw. Ct. 2016). “2 Background Section 8565(c) of the act commonly referred to as the Consolidated First Class County Assessment Law, 53 Pa.C.S. § 8565(c), requires the City of Philadelphia’s Office of Property Assessment (OPA) to issue notices of real estate assessment changes to registered…”

Liberty Place Retail Assoc. v. City of Philadelphia ~ Appeal of: Bd. of Rev. of Taxes (Pa. Commw. Ct. 2019). “er of commercial property owners, lessees, or responsible taxpayers (Plaintiffs) filed 13 lawsuits seeking refunds of the increased taxes, alleging that the City’s selective reassessment violated the Uniformity Clause of Article 8, Section 1 of the Pennsylvania Constitution,…”

— 53 Pa. Cons. Stat. § 8565(b)(1) — 1 case

Starwood Airport Realty v. Sch. Dist. of Philadelphia, 115 A.3d 410 (Pa. Commw. Ct. 2015). “at 2 (citing 53 Pa.C.S. § 8565(b)(1).)) Thus, Starwood’s tax liability for the 2013 tax year increased back to the pre-appeal level.”

— 53 Pa. Cons. Stat. § 8565(b)(2) — 2 cases

Duffield House Assoc., L.P. v. City of Philadelphia ~ Appeal of: City of Philadelphia & S.D. of Philadelphia (Pa. Commw. Ct. 2021). “In its Complaint, Duffield alleged that the City selectively reassessed only commercial properties at fair market value for Tax Year 2018, in violation of the Uniformity Clause and Section 8565(b)(2) and (c) of the Consolidated First Class County Assessment Law (Assessment Law),…”

— 53 Pa. Cons. Stat. § 8565(c) — 3 cases

A. Collier v. City of Philadelphia, Bd. of Revision of Taxes (Pa. Commw. Ct. 2017). “However, Section 8565(c) of the statute known as the Consolidated First Class County Assessment Law (Consolidated Assessment Law), 53 Pa. C.S. §8565(c), states that “[n]otwithstanding any other provision of law, for tax years after tax year 2013, the [OPA] shall certify assessed…”

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