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Commercial Property Tax Protest in Texas (2027 Guide)
Protest Process

Commercial Property Tax Protest in Texas (2027 Guide)

Commercial Property Tax Protest in Texas

A commercial property tax protest is how a Texas business owner or real estate investor challenges the value the county appraisal district puts on an office building, retail center, warehouse, apartment complex or other commercial property. Whether you own the building your business operates in or property you rent to tenants, property tax is usually one of your largest operating costs, and often the single largest. Commercial property gets no homestead exemption and no 10% appraisal cap, and in most Texas cities a combined tax rate of about 2% applies to every dollar of value. When you pay that bill yourself, every dollar the value comes down goes straight to your bottom line.

This guide is written for commercial property and business owners. It covers what a reduction is worth to your cash flow and property value, how appraisal districts value commercial property, the arguments that win reductions, what to check for each property type (apartments and rental portfolios, retail and investment property, office, industrial, owner-occupied business property, hotels and land) and the 2027 deadlines. If you own a home, see our residential vs. commercial property tax guide instead.

Quick Answers

  • Who can protest: any owner of commercial real estate or business personal property in Texas, or an agent they authorize
  • 2027 deadline: May 15, or 30 days after your Notice of Appraised Value was delivered, whichever is later. May 15, 2027 is a Saturday, so the deadline moves to Monday, May 17, 2027
  • Main grounds: market value (the value is higher than the property would sell for) and unequal appraisal (it is valued higher than comparable properties)
  • Key evidence: income and expense statements, rent roll, vacancy history and same-use comparable properties
  • Cost to file: free. The ARB cannot raise your value because you protested
  • What a reduction is worth: the tax savings every year the lower value holds, plus higher net operating income. At a 7.5% cap rate, each $1,000 of annual savings supports about $13,300 of property value
  • Cost to hire Ballard: 1% of the assessed value reduction we achieve, nothing upfront

Own commercial property? Start your commercial property tax protest. You pay 1% of the reduction we achieve, and nothing if your value doesn't come down.

What Is a Commercial Property Tax Protest?

Every January 1, your county appraisal district (CAD) sets a market value for each property in the county. Local taxing units then apply their tax rates to that value. A protest is a formal challenge to that value (your commercial property tax assessment), filed with the CAD and decided by its appraisal review board (ARB) if it isn't settled first.

The filing steps are the same for every property type (see our Texas property tax protest guide). What sets commercial protests apart is how the value is built, which evidence moves it and how much money is at stake.

Why Commercial Owners Should Protest Every Year

Commercial property pays the full rate on the full value. Commercial property tax is calculated as the appraised value times the combined rate of every taxing unit that covers the property. No homestead exemption or 10% cap applies, so the bill tracks the appraised value directly. At 2026 adopted rates, the Texas commercial property tax rate in major cities ranges from about 1.6% to 2.4%. See the full list in our Texas property tax rates by county guide.

Appraised value Tax at a 2.0% combined rate Savings from a 10% reduction
$750,000 $15,000 $1,500 a year
$2,000,000 $40,000 $4,000 a year
$5,000,000 $100,000 $10,000 a year

The 20% cap is scheduled to end. Since 2024, non-homestead real property valued at or below a threshold ($5,320,000 for 2026) has had its appraised value increases capped at 20% a year. The cap is set to expire December 31, 2026 unless the Legislature extends it in the 2027 session. If it lapses, there is no limit on how much a commercial property's value can rise in a single year, and protesting becomes the only check on an increase. Properties above the threshold never had the cap. See our 2026 Texas property tax law changes for details.

Mass appraisal misses details. CADs value thousands of commercial accounts with models built on market-wide rents, vacancy and cap rates. Those models can't see a lease that is below market, a tenant that left in December, a roof that needs replacing or a building that is a different use than its neighbors.

What a Commercial Property Tax Reduction Is Worth to Your Bottom Line

When you pay the property tax yourself, a lower appraised value shows up in four places:

  • Cash flow. The tax bill, or the monthly tax escrow on your loan, drops by the reduction times your combined rate.
  • Net operating income. Property tax is an operating expense. For apartments, RealPage estimates taxes run about 30% of total operating expenses, and they are often the largest single line item for offices and retail too. Every dollar of savings raises NOI by a dollar.
  • Property value and financing. Commercial property is valued and financed on NOI. At a 7.5% cap rate, each $1,000 of annual savings supports about $13,300 of value, and a higher NOI improves your debt service coverage ratio when you refinance. Buyers often underwrite taxes based on the price they pay, so treat this as support for value rather than a guaranteed gain.
  • Next year. The appraisal district starts next year's value from where this year's settled, so a reduction keeps paying off.

Example: an office building appraised at $4,000,000 is reduced to $3,600,000 at a 2.0% combined rate.

Item Amount
Value reduction $400,000
Annual tax savings $8,000
Ballard fee (1% of the reduction) $4,000
Net savings in the first year $4,000
Value supported by the higher NOI at a 7.5% cap rate About $106,700

How Texas Appraisal Districts Value Commercial Property

Commercial property can be valued three ways, and each can produce a very different number. Knowing which one the CAD used tells you what evidence will move it.

Income Approach

The income approach is the standard method for income-producing property: offices, retail centers, industrial buildings, apartments and hotels. It values the property by the income it can produce.

Property Value = Net Operating Income / Capitalization Rate
Component Amount
Potential gross income $300,000
Less vacancy and collection loss (10%) -$30,000
Effective gross income $270,000
Less operating expenses -$70,000
Net operating income (NOI) $200,000
Capitalization rate 8.0%
Indicated value $2,500,000

Small changes in the inputs move the value a lot. At a 7% cap rate instead of 8%, the same building is valued at $2,857,000. That $357,000 difference costs about $7,100 a year in taxes at a 2% combined rate.

Where income-approach values go wrong:

  • Market rent set above what the property actually collects
  • Vacancy and collection loss set below the property's real vacancy
  • A cap rate that is too low for the property's age, location or tenant risk
  • Missing expenses: management, reserves, tenant improvements and leasing commissions

Cost Approach

Property Value = Land Value + (Replacement Cost - Depreciation)

The cost approach is used for newer buildings, special-purpose property (churches, schools, auto dealerships) and property that rarely sells or has no rental history. It is often wrong when it uses current construction costs without enough depreciation, or ignores functional obsolescence (outdated layout, low ceiling heights, too little parking) and economic obsolescence (a declining corridor, a rerouted highway, nearby environmental problems).

Sales Comparison Approach

The sales comparison approach compares your property to recent sales of similar properties, adjusted for size, age, condition and location (see how comparable properties are used). It works best for small commercial buildings and land. It is harder to use for larger commercial property because commercial sales are less frequent, no two properties are alike and Texas is a non-disclosure state, so sale prices are not public record.

The Strongest Grounds for a Commercial Protest

Unequal Appraisal

Under Texas Tax Code Section 41.43(b), a property's appraised value can't be more than the median appraised value of a reasonable number of comparable properties, appropriately adjusted. That is an unequal appraisal (or equity) argument, and it is often the strongest one for commercial property because:

  • It uses the appraisal district's own values, so the CAD can't dispute the source
  • It doesn't require proving what the property would sell for, which matters in a non-disclosure state
  • It works even when the property is valued at or below market value

The key is choosing comparables of the same use, not just the same quality class. A warehouse should be compared to warehouses, not to banks or restaurants in the same quality grade, which carry much higher values per square foot. The usual measure is appraised value per square foot of building area.

Example: a 20,000 sq ft warehouse appraised at $3,200,000 ($160 per sq ft). Six same-use warehouses in the same market area have a median of $142 per sq ft. The equity value is 20,000 x $142 = $2,840,000, a $360,000 reduction worth about $7,200 a year at a 2% rate. At Ballard's 1% fee, that protest would cost $3,600.

If the same-use median is at or above your value, an equity argument won't help, and the case needs to be built on market value instead. Learn more about how unequal appraisal works.

Market Value

The market value argument is that the CAD's value is higher than the property would sell for on January 1. For commercial property, that usually means rebuilding the CAD's income approach with your actual rents, vacancy and expenses and a market-supported cap rate, or showing sales of comparable properties at lower prices.

Errors in the Property Record

Check the CAD's property record before anything else. Common commercial errors:

  • Wrong building area or net leasable area
  • Wrong year built or effective age
  • Wrong property use or quality class (for example, Class A office for a Class B building)
  • Missing condition adjustments for deferred maintenance
  • Wrong unit count on multifamily property

A single wrong number can overstate a commercial value by hundreds of thousands of dollars.

Commercial Property Tax Protests by Property Type

Every commercial protest uses the same grounds and the same deadline, but what the appraisal district gets wrong depends on the property. Use this table to find the first thing to check, then see the section for your property type.

Property type How CADs usually value it First thing to check
Apartments and rental portfolios Income approach (5+ units); sales comparison (1 to 4 units) Market rent and vacancy vs. your rent roll
Retail and investment property Income approach Vacancy, rents in place and leasing costs
Office Income approach Building class, concessions and vacancy
Industrial, warehouse and flex Income or cost approach Same-use comparables and building features
Owner-occupied business property Cost or sales comparison approach Depreciation, obsolescence and double counting
Hotels Income approach Business value included in the real estate
Vacant and development land Sales comparison Floodplain, access and utilities

Your financials stay confidential. Under Texas Tax Code Section 22.27, income and expense information you give the appraisal district is confidential and can't be released to the public.

Tenant-Occupied Residential: Apartments and Rental Portfolios

This covers apartment complexes of five or more units and investors who own portfolios of single-family rentals, duplexes or fourplexes. Property tax is usually the largest expense on an apartment operating statement, and rents can't be raised mid-lease to cover an increase, so a higher appraisal comes straight out of NOI and debt service coverage.

The CAD values apartments of five or more units with the income approach, usually built on market rents per unit or per square foot and a market cap rate. Smaller rentals are valued like homes, with sales comparison, and get no allowance for tenant wear or rental condition.

Where the value goes wrong:

  • Market rent set above your effective rent after concessions
  • Vacancy and bad debt set below what the property actually loses
  • An expense ratio that ignores how much insurance, payroll and repairs have risen
  • Wrong unit count, unit mix or rentable square footage
  • An older property valued at the same rate per unit as newer complexes nearby

Evidence: a trailing 12-month (T-12) operating statement, current rent roll, concession and occupancy history, repair bids for deferred maintenance and a same-use equity analysis by value per unit and per square foot.

Each rental in a portfolio is its own account with its own protest, and every one needs to be filed each year. For details on single-family rentals, duplexes and other small investment property, see our rental and investment property tax protest guide.

Retail Centers and Other Investment Property

This includes strip and neighborhood centers, single-tenant buildings leased to restaurants, pharmacies or banks, and small mixed-use buildings held for income. Property tax on investment property like this is usually the largest expense after debt service, and when you pay it yourself, every increase cuts cash-on-cash return and the distributions you or your investors take home.

Where the value goes wrong:

  • Vacancy set below actual, especially in centers with a dark anchor or long-vacant suites
  • Market rents applied to leases that renewed below market
  • No allowance for the leasing commissions, tenant improvements and free rent needed to fill vacant space
  • A single-tenant building valued off sale prices driven by a long lease to a national tenant, where the price reflected the lease and not just the building

Evidence: rent roll, lease abstracts, vacancy and downtime history, leasing cost history and same-use equity comps.

Office Space

This includes multi-tenant office buildings, medical office and owner-user office buildings and condos. Office vacancy remains high in many Texas markets, and landlords are giving larger concession packages to sign tenants. Appraisal district models are often slow to reflect both.

Where the value goes wrong:

  • Building class set too high (for example, Class A rents applied to a Class B building)
  • Asking rents used without subtracting free rent and tenant improvement packages
  • Vacancy set at a market average below the building's actual vacancy
  • No allowance for the cost and time to lease up vacant space
  • Medical or specialized build-out valued at replacement cost without functional obsolescence
  • Wrong net rentable area

Evidence: a rent roll with effective rents, concession and TI history, vacancy history, leasing costs and equity comps of the same class and size.

Industrial, Warehouse and Flex

This includes warehouses, distribution buildings, small-bay and flex industrial and self-storage. Industrial values have climbed quickly in many Texas markets, and industrial property tax bills with them. CADs often value older, smaller buildings at rates set by new bulk distribution space.

Where the value goes wrong:

  • Comparison to newer buildings with higher clear heights, more dock doors and larger truck courts
  • Office finish percentage overstated
  • Functional obsolescence ignored: low ceilings, poor truck access, limited power or too little parking
  • Wrong building area or site size

Evidence: building specifications, photos and a same-use equity analysis by value per square foot. The warehouse example in the unequal appraisal section above shows how a same-use comparison works.

Owner-Occupied Business Property

This includes restaurants, auto dealerships and repair shops, retail stores, medical and dental practices, day cares, car washes and other buildings your business operates from. There's no tenant to share the cost, so a higher tax bill comes straight out of your business's margins. Many owners pay through a mortgage escrow and only see the increase when the payment changes.

Where the value goes wrong:

  • The cost approach applied with current construction costs and too little depreciation
  • Special-purpose features valued at full cost, even though a buyer wouldn't pay for them
  • Business value, or equipment already reported on your business personal property rendition, counted again in the real estate value
  • Comparison to buildings of a different use with higher values per square foot

Evidence: year built, renovation history, condition photos, same-use equity comps and a check that your equipment and fixtures aren't counted on both the real estate and personal property accounts.

Hotels and Hospitality

The CAD values hotels with the income approach based on room revenue. Owners care about the swings in occupancy and average daily rate that a one-year model can miss.

Where the value goes wrong:

  • Business income (franchise affiliation, management and brand value) included in the real estate value
  • Furniture, fixtures and equipment counted in both the real estate and the personal property
  • Occupancy and room rates set above the property's actual performance
  • No allowance for a brand-required renovation (property improvement plan)

Evidence: profit and loss statements, STR or other occupancy and rate reports, franchise and management fee schedules and any property improvement plan.

Vacant and Development Land

The CAD values land with sales comparison, often on a flat price per square foot or per acre across a neighborhood.

Where the value goes wrong:

  • Floodplain, easements, poor access or a lack of utilities ignored
  • Odd shape, topography or zoning limits not adjusted for
  • Land that qualifies for agricultural or timber appraisal valued at market value

Evidence: land sales with adjustments, survey and floodplain maps, utility availability letters and zoning information.

How to Protest Commercial Property Taxes: Step by Step

  1. Review your Notice of Appraised Value. Notices go out in April and May. Compare this year's value to last year's and check the property record for errors.
  2. File a Notice of Protest by the deadline. File online through your CAD's portal or with Comptroller Form 50-132. Check both "value is over market value" and "value is unequal compared with other properties" so you can make either argument.
  3. Request the CAD's evidence. Under Tax Code Section 41.461, you can request the evidence the appraisal district will use at your hearing. It must be available at least 14 days before the hearing. Check which approach they used, their rent, vacancy, expense and cap rate assumptions and their comparables.
  4. Build your evidence packet. Match it to the approach the CAD used. Prepare an equity analysis whenever same-use comparables support one.
  5. Negotiate at the informal review. Most commercial protests are settled with a CAD appraiser before the ARB hearing.
  6. Present your case at the ARB hearing. If the informal offer isn't acceptable, a panel of the appraisal review board hears both sides and sets the value.
  7. Appeal if needed. See the next section.

2027 Commercial Protest Deadlines

Step 2027 date
Business personal property rendition due April 15 (extension to May 15 on written request)
Notices of Appraised Value mailed April to May
Protest deadline May 15, or 30 days after the notice was delivered, whichever is later. May 17, 2027 for most owners, because May 15 is a Saturday
Informal reviews and ARB hearings May to September
Appeal after the ARB order Within 60 days of receiving the order

Some appraisal districts set different dates for certain accounts. Check your notice and your county's dates: Texas property tax protest deadlines.

After the ARB: Commercial Property Tax Appeals

In Texas, the protest is the stage before the appraisal district and the ARB. An appeal comes after the ARB issues its order. Other states call the whole process a "commercial property tax appeal." Commercial owners have three appeal options:

Option Who can use it Notes
Binding arbitration Property valued at $5 million or less Filed through the appraisal district within 60 days of the ARB order; refundable deposit
State Office of Administrative Hearings (SOAH) Property valued over $1 million Notice due 30 days after you receive the ARB order; $1,500 deposit
District court Any property Filed within 60 days; usually requires an attorney and appraisal expert

For arbitration and court appeals, you generally must pay the undisputed portion of your taxes before the delinquency date to keep the appeal alive.

Business Personal Property Is Protested Separately

Furniture, equipment, inventory and other business personal property (BPP) are taxed separately from the real estate and have their own account. You report them on a rendition (Form 50-144) due April 15. Starting with the 2026 tax year, Texas exempts up to $125,000 of business personal property from taxation. BPP values can be protested on the same deadline as the real estate. See does Texas have a personal property tax?

When to Hire a Commercial Property Tax Consultant

You can protest on your own, and owners of small, simple properties often do. Professional help makes the most sense when:

  • The CAD used the income approach and you disagree with its rent, vacancy, expense or cap rate assumptions
  • An equity analysis needs CAD data across dozens of same-use properties
  • You own several commercial properties or a portfolio across counties
  • The case may go to arbitration, SOAH or district court

Licensed property tax consultants handle most commercial protests through the ARB stage, usually on contingency. Attorneys matter most once a case goes to district court. Our comparison of Texas property tax protest companies explains how fees and services differ.

Protest Your Commercial Property Taxes With Ballard

Ballard Property Tax Protest handles commercial property tax protests for Texas business owners and investors. We pull the appraisal district's own data to build same-use equity analyses, review the CAD's income assumptions and handle your informal review and ARB hearing.

Our fee is 1% of the assessed value reduction we achieve on your protest. There's no upfront cost, and if we don't lower your value, you don't pay.

Start your commercial property tax protest

Matthew Ballard
Matthew Ballard

Licensed Property Tax Consultant - TDLR #12593

Matthew Ballard is the founder of Ballard Property Tax Protest and has helped thousands of Texas homeowners reduce their property tax bills. He specializes in residential property tax protests across 18 Texas counties.

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