According to the Council of Europe (2003), around 65 per cent of cultural heritage sites and buildings in Europe are under a private property rights regime. A similar picture emerges from the rest of the developed world (Pickard, 2009): in the United States and Canada, private sector involvement in the conservation of heritage is extensive and pre-dates formal government intervention; in Australia, the majority of historic heritage places on statutory lists of the Federal, State and Territory governments are under private ownership (Australian Government Productivity Commission, 2006). This widespread property rights structure forcefully raises the issue of the desirability, as well as of the effectiveness, of systems of tax incentives to private owners, with the objective of preserving cultural resources in the wider community interest. In that regard, the Council of Europe (2003) emphatically asserts that ‘where necessary that owner should be given whatever support and encouragement the wider community might be able to offer’, and the US National Historic Preservation Act of 1966 declares that ‘it shall be the policy of the Federal Government to contribute to the preservation of nonfederally owned prehistoric and historic resources and give maximum encouragement to organizations and individuals undertaking preservation by private means’.
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