Hi Maria
In my opinion that is a pretty narrow view of “a subsequent year” paying attention to “a”. If the act only wanted to charge for two years I believe it would have been more prescriptive. Remember until its tested in court it is only an opinion.
I have had a similar case and will be backdating the rates to the date of transfer. We have a copy of the 603 certificates which states that the non rateable property would be rated from the date of transfer.
Have you also looked at section 572 regarding change of rateability?