<p>This study aims to analyze in determining the basis of imposition of the Land and Building Transfer Tax (BPHTB) on buying and selling through the implementation of verification and the constraints that occur in its implementation in the Regional Revenue Agency (Bapenda) Office of Bandung City. The method of study used was a qualitative research method. The data processing used a method developed by Miles and Huberman, which are data reduction, data presentation, and drawing a conclusion. The results of this study are the basis for imposing BPHTB using NPOP (Tax Object Acquisition Value), the price of tax object transaction or the market value of tax object. The constraints that occur in the implementation in determining the basis for imposing BPHTB are insufficient quantity of human resources, the differences of the price proposed by taxpayers with the estimated value assigned by Bapenda, the lack of field survey techniques used in determining the reasonable price, no definite indicator in determining estimated price, and the delay in the process of transferring rights to land and building. The suggestions that can be provided by the researcher are that the Regional Revenue Agency (Bapenda) of Bandung City needs to analyze the need of employees and the division of workload accurately, publish applicable market bank data to be a basis for the comparison of the reasonable transaction price, and make a taxpayer risk profile system to obtain wider data access. Moreover, Bandung Government should conduct a review of the legal certainty for the BPHTB collection system.</p>