房地产税（房地产保有环节税）是以房地产的市场价值为依据、在房地产保有环节向房屋产权所有人征收的财产税。房地产税政策是由国家制定的一项针对居民住房征税的公共政策。
自我国政府提出实施房地产税政策主张以来，学界提出了许多反对意见，有两个反对征税的观点最受人关注：一是房子是私有的，土地是国有的，房主没有房地产所有权，所以，对房主征税不合理；二是政府收取了土地出让金，又要征房地产税，会形成重复征收，所以，我国征收房地产税不合理。
有学者对我国房地产税政策的合理性进行了论证，但论证存在不足、解释力不强。一是部分论证缺乏针对性，没有正面回应反对者观点。二是部分论证深度不够，对问题的本质认识不足，没有认识到土地供给弹性小的特性和房地不可分的特点，进而无法认识到城市房地产中利益产生和分配的实质。本文从地租归公的视角对我国房地产税政策的合理性进行重建，为我国房地产税政策早日出台提供支持。
地租是由于土地的供给弹性小而产生的超额利润。在城市中，由于地理位置的差异而产生的超额利润是级差地租I，在一块土地及其周边土地上连续追加投资所产生的超额利润为级差地租Ⅱ。地租归公学说认为，政府应该将地租收归公有，进而将地租用于公共支出，由社会成员共享。在历史的实验场中，有两种实现地租归公的模式，一种是马克思和恩格斯所主张的制度模式：土地公有制+住房公有制；另一种是地价税（土地价值税）模式。我国改革开放之前曾经采用过第一种模式，虽然实现了地租归公，但产生了效率缺失、资源浪费等问题。改革开放后，我国进行了土地和住房制度改革，改革推动了经济社会的快速发展，但出现了城市地租大量归私的问题。
房地产税（保有环节税）依据房地产的市场价值征税，是一种地价税，而地价是地租的资本化，所以，房地产税实质是对地租征税，且由于土地的供给弹性小，房地产税不易被转嫁。房地产税是一种公平、有效率的税，它能够成为我国实现城市地租归公的新的政策选择。
针对反对者的观点，本文提出，房与地不可分离，地租跟随私有房产走，私人虽然没有土地所有权，但拥有土地使用权和房屋所有权，私人可以在保有住房的过程中获得地租。房地产税的实质是将地租归公，所以，公有土地上也可以征房地产税；房主购买房产时所付的价格中包含了土地出让金，但土地出让金属于级差地租I（由于地理位置的差异而产生的超额利润）。随着政府对基础设施、公共服务持续投入，级差地租Ⅱ会源源不断的产生，政府没有将新增级差地租Ⅱ收回，房地产税征收的是新增级差地租Ⅱ，所以，房地产税不是重复征收。
本文的创新之处在于认识到房地产保有者通过房地产获得的巨额收益本质上是地租，这种收益是由于土地的供给弹性小而产生的，房主虽然不拥有土地所有权，但房主拥有土地使用权，房屋和土地不可分离，房主凭借房地产便可以获得土地带来的收益——地租。

Real estate ownership link tax is a property tax levied on property owners in the link of real estate ownership based on the market value of real estate. Real estate tax policy is a public policy that is formulated by the state to levy taxes on residents' housing.

Since our government put forward the policy of levying real estate tax, the academic circles have raised many opposing opinions. Two opposing opinions are the most concerned: one is that the house is private, the land is state-owned, and the owner has no real estate ownership, so it is unreasonable to tax the owner; Second, the government collected the land transfer fees, but also to levy real estate tax, will form a repeated collection, so, China's collection of real estate tax is unreasonable

Some scholars have demonstrated the reasonableness of China's real estate tax policy, but the demonstration is not strong enough to explain.First, part of the demonstration is lack of pertinence and does not respond to the opponents' views positively. Second, part of the demonstration is not deep enough and has insufficient understanding of the nature of the problem. It fails to recognize the characteristics of small elasticity of land supply and indivisibility of premises, thus failing to recognize the essence of the generation and distribution of interests in urban real estate This paper reconstructs the rationality of China's real estate tax policy from the perspective of transferring land rent to the public and provides support for the early introduction of China's real estate tax policy

Land rent is the excess profit due to the small elasticity of land supply.In cities, the excess profit generated by the difference in geographical location is the differential rent I, and the excess profit generated by continuous additional investment in a piece of land and its surrounding land is the differential rent Ⅱ.Theories think that the government should be under the public land rent, which will rent for public spending, Shared by members of the society in the experiment field of history, there are two patterns of realizing rent to the public, One is the institutional model advocated by Marx and Engels:Public ownership of land and public ownership of housing; The other is the land price tax model.China used the first model before the reform and opening up, although realized the land rent down, However, problems such as lack of efficiency and waste of resources have arisen.After China's reform and opening up, China has carried on the land and housing system reform, establish the real estate market, promoted the rapid development of economic and social reform, but also brings the enormous urban land rent to private .

Real estate tax (retention link tax) is levied according to the market value of real estate. It is a kind of land price tax, and the land price is the capitalization of land rent. Therefore, the real estate tax is essentially a tax on land rent. And because the elasticity of land supply is small, the real estate tax is not easy to transfer. Real estate tax is a kind of fair and efficient tax, which can become a new policy choice to realize the public ownership of urban land rent in China.

This paper holds that in China, although private people have no land ownership, they have the right to use the land and the right to own the house. In the process of holding the house, private people can get the rent.According to the theory of public ownership of land rent, real estate owners should pay real estate tax. The land transfer fee, which is part of the price a homeowner pays to buy a property, is classified as differential rent I and has been taken into public ownership by the government.As the government continues to invest in infrastructure and public services, the price of urban land will continue to rise, and the differential rent Ⅱ will be continuously generated. For this part of new rent, the government does not take it back, and the real estate tax is to take this part of new differential rent into public ownership.Therefore, it is reasonable for China to levy real estate tax .

The innovation of this paper lies in the recognition that the huge income that the real estate owners get from real estate is essentially the land rent, which is generated because of the small elasticity of land supply.Although the owner does not own the land, but the owner has the right to use the land, The house and the land are inseparable, and the owner can obtain the income from the land rent by relying on the real estate.