Abstract: There are many structural problems in China's current real estate tax system， such as fragmented rules， narrow scope of taxation and unfair distribution of tax burden， but due to the failure to clarify the justification basis for the establishment of real estate tax， the expansion of the system and optimization of the structure of this tax have been stagnant for a long time， which has led to local financial risks and wealth inequality issues that cannot be ignored. In order to ensure and promote the intergenerational equity of the civil space development right， the institutional construction of a broad-based real estate tax should not only focus on the differentiated target orientation of the tax in the context of council tax and property tax， but also clarify the differences between the legal and economic attributes of buildings and land， especially the narrow and broad residential interests carried by residential real estate. This can be used to explore tax design schemes centered on the “real estate separatism”， so as to better measure and capture the spatial value and natural appreciation of real estate， thereby eliminating reasonable doubts and legitimate criticisms from all sectors about the new economic burden.

Key words: real estate tax; real estate separatism; civil space development right; ability-to-pay principle; tax equity