A tax on the debt, not on the sale
Where the transfer tax reaches the deed that conveys the land, the intangible recording tax reaches the instrument that secures the loan. O.C.G.A. 48-6-61 imposes it at $1.50 for each $500 or fraction thereof of the face amount of the note, which is the familiar $3 per $1,000. The lender is the taxpayer, but the cost is commonly passed to the borrower at closing. The statutory maximum is $25,000 per note, which is not reached until the note is $8,333,333.34 or more.
Worked example
A $300,000 note: $300,000 ÷ $500 = 600 units; 600 × $1.50 = $900.00.
The most common error is swapping in the transfer tax rate of about $1 per $1,000, which would give $300.00. Halving the rate to $1.50 per $1,000 gives $450.00. Neither is the intangible rate.
"Or fraction thereof" means round up
Because the statute taxes each $500 or fraction thereof, a partial unit is a whole taxable unit.
Worked example: a note of $265,250. $265,250 ÷ $500 = 530.5 units, which rounds up to 531. 531 × $1.50 = $796.50. Leaving the fraction untouched at 530.5 units gives $795.75 — the trap answer. Multiplying the units by $1.00 instead of $1.50 gives $530.50.
Only long-term notes are taxed
O.C.G.A. 48-6-60 defines a long-term note as one in which any part of the principal falls due more than three years from the date of the note or the security instrument. A note whose entire principal comes due within three years is short-term and owes no intangible recording tax at all.
So a 24-month note secured by a security deed owes nothing. Not every secured note is taxed — the long-term limitation in 48-6-61 controls. And there is no half rate for short notes; the choice is the full $1.50 per $500 or nothing.