Key property tax deadlines and tips for commercial property owners and asset managers in Manitoba

Under Manitoba legislation, properties were reassessed for 2023 based on values as of April 1, 2021. However, as 2024 is the second year of the two-year assessment cycle, property owners will not receive an assessment notice unless there has been a change in value or other change from the 2023 roll (e.g. ownership change). To take advantage of all opportunities to reduce your 2024 property tax, you should conduct a thorough review of both property and business assessments, be aware of the deadlines to appeal, and ensure that you correctly file your response to the Assessor’s income and expense requests.

At a glance – key information for property tax in Manitoba:

• Current assessment cycle (2023-2024)

• Reference date: April 1, 2021

• Deadline to appeal 2024 property tax in Winnipeg is June 27, 2023

• Outside Winnipeg, property tax appeal deadlines are expected to be between August-November 2023, and will be posted on the Manitoba Assessment Service (PMA) website

• Business tax appeal deadline is anticipated to be in November of 2023

• Assessor 2022 information request deadline for Winnipeg is May 4, 2023 (request extension ASAP if needed)

• For properties outside Winnipeg, the deadline to reply to the Assessor’s 2022 information request is printed on the request letter

Why you should consider filing an appeal for 2024 taxation

As aforementioned, the valuation date (called the “reference date” in Manitoba legislation) for the 2024 assessments is April 1, 2021. As of that date, the economic impacts of the pandemic were profound for properties in many market sectors, and your assessment for property tax should reflect those impacts. The deadline to appeal the 2024 assessments of Winnipeg properties is June 27, 2023 at 4:30 pm. Outside Winnipeg, appeal deadlines have not yet been set, but are expected to vary from August to early November of 2023.

Although there was no reassessment for 2024, there are several reasons you should consider filing an appeal this year: 

1. If you received notice of a new value for 2024

2. If you missed the opportunity to file an appeal for 2023

3. If you are not satisfied with the result of your 2023 Application for Revision

4. If you have not yet had a third-party review, or are interested in a second opinion to confirm your assessed value is accurate and in line with competing properties

Why and how you should reply to Assessor requests for income information

The Province of Manitoba (PMA) and the City of Winnipeg have sent requests for 2022 income and expense and rent roll information to owners of commercial, multi-residential and industrial properties. This information will be used to determine assessed values for the 2025-2026 assessment cycle. If you don’t file your reply correctly prior to the deadline, you may face a substantial penalty for non-compliance with the request, which equals the forfeiture of an entire year’s tax savings on appeal.    

For the first time, the City Assessor has not included the full pre-printed form with his request for 2022 information. Rather, a single letter has been sent with instructions as to how to prepare and send replies to his request. Copies of the standard Income and Expense Questionnaire are still available for download from the Manitoba Assessment Services and Winnipeg City Assessor.

When reviewing and responding to the Assessor’s information request, you should keep these things in mind: 

• You must comply with the deadline or seek an extension: The deadline for submission will be printed on the request. The stated deadline to reply to the requests for 2022 information for Winnipeg properties was May 4, 2023. If you have not yet sent your reply, we strongly recommend that you send a written request for an extension to the PMA or City Assessor immediately. You should reference each roll number and address for which an extension is requested. 

• You must provide a response for an owner-occupied property: Although the standard forms included with the Assessor’s requests include tenant verification and rental income segments, owner-occupants must also reply to the requests for information. The “Owner Occupied” box should be checked off and property operating expenses must be submitted. 

• You need to ensure that you identify the property on any forms or documents submitted: In the past, the Assessor supplied forms that were pre-populated with property identification data. This year, however, the standard form will not have this information. With this in mind, if you are using these forms or are submitting income statements and rent rolls generated from your own systems, you will need to ensure that the full address and roll number of each property is indicated on all of the documents.

• You could face a significant penalty for non-compliance: The Board of Revision and Municipal Board have been imposing penalties for non-compliance with the Assessor’s requests for information, the most significant of which is the forfeiture of a full year’s tax savings on appeal where a failure is found. This can be an exceptionally costly penalty if a significant reduction in the assessment is achieved on appeal.

Don’t forget the business tax

Owners of business property in the City of Winnipeg are also liable for a business tax.  Your 2023 business tax bill should have been received in May. Assessments for business tax are calculated based on an “Annual Rental Value” which is comprised of a market net rent plus standard occupancy costs for utilities. Taxes and business improvement zone levies are calculated based on the Annual Rental Value.  

The Small Business Tax Credit threshold for 2023 is $47,500. You are not required to pay base business tax for this portion of your Annual Rental Value – and if your value is less than this amount, you will not be liable for base business taxes. Business Improvement Zone levies are payable based on your full Annual Rental Value.   

The appeal deadline for Winnipeg business assessments usually falls in November, but has not yet been announced. Your 2023 bill can be used to initiate a review of your business tax assessment.