Confusion still arises among appraisers and even notaries: should every appraisal report be registered in the Unified Database of the State Property Fund of Ukraine, or only certain cases?
Some think that any property appraisal must be registered. Others believe it applies only to sales. This leads to unnecessary actions, mistakes, and misunderstandings with clients.
To clarify this issue, an official written explanation from the State Property Fund of Ukraine was obtained — a response to the inquiry of our colleague appraiser Mykola Mozhirovskyi. Below, we explain the meaning of this position in plain language.
The original SPFU response is shown below.
Main Principle: The Database Is Not for All Appraisals
The Unified Database of appraisal reports is not intended to control all appraisers or to register every property appraisal.
Its primary purpose is monitoring the taxation of individual income.
Simply put, the database is needed by the state when an appraisal is used for tax calculation.
Important: this concerns individuals only. This is explicitly stated in the official SPFU response.
When an Appraisal Report MUST Be Registered
According to the State Property Fund, reports must be registered if they are prepared to determine the income of an individual taxpayer and if this income is taxable.
The key criterion is the presence of tax consequences for an individual.
Sale or Exchange of Property
When an individual sells an apartment, house, land plot, or other property, the tax is calculated based on the appraised value. Therefore, the report must be registered in the Unified Database.
Inheritance or Gift (if taxed)
If property is inherited or received as a gift and the operation is subject to taxation (i.e., the tax rate is not zero), the appraisal is used to determine the tax base, and the report must be registered.
Other Transactions Involving Property Ownership Transfer
If ownership of property changes and the individual earns taxable income — the report must also be registered.
When a Report Does NOT Need to Be Registered
The State Property Fund explicitly stated that appraisal reports prepared not for determining an individual’s taxable income do not need to be registered in the Unified Database.
In other words, most professional appraisals are unrelated to this database.
For example:
- Appraisals for court;
- Appraisals for accounting purposes;
- Revaluation of company assets;
- Appraisals for credit;
- Contribution of property to the charter capital;
- Determination of damages;
- Internal corporate transactions;
- Expert conclusions without tax purposes.
Special Case: If the Owner Is a Legal Entity
The official SPFU response highlights an important practical point:
The Unified Database applies only to individual income.
Therefore, if the property owner is a legal entity and the appraisal is not related to determining taxable income for an individual, registration in the Unified Database is not required.
The mere fact that property is appraised does not create a registration obligation.
Why Confusion Arises
Many focus on the type of property — real estate. But the law links registration not to the object of appraisal, but to the purpose of the appraisal.
It’s not the object that determines the need for registration, but the tax consequences for the individual.
What SPFU Actually Confirmed
In its official response, the State Property Fund confirmed:
- The Unified Database is used for taxation purposes;
- It includes reports determining taxable income for individuals;
- Other appraisal reports are not subject to registration.
Conclusion in Simple Terms
If an individual has taxable income — registration is required.
If there is no taxable income — registration is not required.
This is the official position confirmed by the State Property Fund in response to the inquiry of appraiser Mykola Mozhirovskyi.
Frequently Asked Questions
Is it necessary to register an apartment appraisal for court purposes?
No. If the appraisal is not used to determine an individual’s taxable income, registration in the Unified Database is not required.
Is an appraisal required for selling property?
Yes, if the seller is an individual and the appraisal is used to determine taxable income according to the Tax Code of Ukraine.
Should an appraisal report be registered if the owner is a legal entity?
No, if the appraisal is not related to determining taxable income for an individual. The Unified Database applies only in cases of individual income taxation.
Are all property appraisal reports registered?
No. Only reports used to determine taxable income for individuals are included. Other appraisal types are not registered.