Current Comprehensive Real Estate Holding Tax on non-residential property has the following problems: 1) building part of non-residential property is exempt from the tax and 2) land part of non-residential property is separately calculated from other types of land and the tax threshold of the land part is set to 8 billion won which is far higher than those of other types. This study tries to review the problems with comparison of the cases of other countries and simulation analyses. Firstly, the countries of Australia, France, Japan, Sweden, Taiwan, the U.K., and the U.S. do not have favourable tax system for non-residential property such as exemption or lower tax rate. Secondly, in the simulation analyses to examine the horizontal equity, the effective tax rate of the portfolio of non-residential property is found as 20~40% of those of housing and land.