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South Carolina Assessable Transfer of Interest (ATI) Property Tax Exemption

Rödl Tax Matters Volume 2026-1, published January 12, 2026

As we enter a new tax year, we would like to remind you of the potential 25% exemption from South Carolina property taxes on commercial real estate newly acquired during 2025. If you purchased commercial real estate in 2025 in the state of South Carolina, this exemption may benefit you. The deadline to apply for 2025 ATI exemptions is January 30, 2026.

The law allows a purchaser of qualifying commercial real estate to reduce the ATI assessed value that is based on the purchase price thereby reducing South Carolina property tax liability. The assessed value exemption can be as much as 25% of the ATI fair market value of the property. Without applying for the exemption, the assessed value of commercial real estate will normally be increased to the full purchase price of a property.

Qualifying commercial real estate includes any parcel of commercial or rental real property and any improvements thereon that undergoes an assessable transfer of interest (for example a sale) during the calendar year (in this case 2025) and is subject to the 6% commercial assessment rate both before and after the transfer. The following will generally not qualify for the ATI Property Tax Exemption:

Real property subject to the 10.5% assessment rate (manufacturing property) either before or after the sale
Tangible personal property
New construction completed in the current year
New construction completed for which a transfer of interest occurred during the calendar year
Property for which the ATI fair market value is lower than the current fair market value
Property under a Fee in Lieu of Tax (FILOT) agreement

The South Carolina Department of Revenue takes the position that the application for exemption must be filed in the first year of eligibility or the exemption is lost for future years. Some recent court cases have allowed a late ATI exemption application in certain limited situations, but this issue is still being litigated. As stated above, the ATI exemption application must be filed by the purchaser with the applicable county where the property is located by January 30, 2026.

If you have any questions, please reach out to your Rödl representative.

This publication contains general information and is not intended to be comprehensive or to provide legal, tax or other professional advice or services. This publication is not a substitute for such professional advice or services, and it should not be acted on or relied upon or used as a basis for any decision or action that may affect you or your business. Consult your advisors. The fact that you have received this publication does not create an accountant-client or advisory relationship between you and Rödl Langford de Kock LLP or any of its subsidiaries or affiliates. If you wish to hire Rödl Langford de Kock LLP or any of its subsidiaries or affiliates you will need to speak with one of our accountants and enter into a written agreement establishing the scope of engagement. We have made reasonable efforts to ensure the accuracy of the information contained in this publication, however this cannot be guaranteed. Neither Rödl Langford de Kock LLP nor any of its subsidiaries nor any affiliate thereof or other related entity shall have any liability to any person or entity which relies on the information contained in this publication, including, but not limited to, incidental or consequential damages arising from errors or omissions. Any such reliance is solely at user’s risk. Any tax and/or accounting information contained herein is based on our understanding of the facts and assumptions we have been asked to make for the purpose of this publication alone, and on the tax laws and/or accounting principles in effect as of the date of this advice. No assurance is given that the conclusions would be the same if the facts or assumptions change, or are not as we understand them, or that the tax laws and/or accounting principles will not change subsequent to the issuance of these conclusions. In addition, we do not undertake any continuing obligation to advise on future changes in the tax laws and/or accounting principles, or of the impact on the conclusions herein. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Rödl Langford de Kock LP.

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