CHANGI AIRPORT GROUP (SINGAPORE) PTE LTD v COMPTROLLER OF INCOME TAX

Q: Which legislation does [2024] SGHC 281 consider?

The judgment refers to Income Tax Act (Cap 134) and UK Customs and Inland Revenue Act. The statutes cited are listed in full on this page, each linking to its primary text.

[2024] SGHC 281 High Court (General Division) 1 November 2024 HC/TA 4/2024 19 min read

5 cases cited (4 SG, 1 foreign)

Key facts

Court	High Court (General Division)
Decided	1 November 2024
Judge	Choo Han Teck
Charges / claim	Revenue Law
Counsel	Inland Revenue Authority of Singapore (Law Division), WongPartnership LLP, Bjorn Lee Long Jin, Flora Koh Swee Huang, Goh Ziluo, Tan Kay Kheng, Tan Shao Tong

Source: [2024] SGHC 281, High Court (General Division), decided 1 November 2024 — eLitigation. Updated 3 July 2026.

Catchwords

Revenue Law — Income taxation — Capital allowance

Practice Areas

Revenue Law

Judges (1)

Choo Han Teck Delivered

Counsel (7)

Inland Revenue Authority of Singapore (Law Division) Firm WongPartnership LLP Firm Bjorn Lee Long Jin Counsel Respondent Flora Koh Swee Huang Counsel Respondent Goh Ziluo Counsel Appellant Tan Kay Kheng Counsel Appellant Tan Shao Tong Counsel Appellant

Parties (2)

Changi Airport Group (Singapore) Pte Ltd Appellant Comptroller of Income Tax Respondent

Case Significance

Changi Airport Group (Singapore) Pte Ltd v Comptroller of Income Tax [2024] SGHC 281 was a tax appeal in the General Division of the High Court (Tribunal Appeal No 4 of 2024) decided by Choo Han Teck J on 1 November 2024, arising from Income Tax Board of Review Appeal Nos 21 to 23 of 2016 and a Grounds of Decision delivered on 7 June 2024. The appellant, Changi Airport Group (Singapore) Pte Ltd, was incorporated in Singapore and appointed in 2009 under the Civil Aviation Authority of Singapore Act 2009 as the successor company for the airport undertaking of the Civil Aviation Authority of Singapore, and has been the licensed aerodrome operator of Changi Airport. The dispute concerned capital allowance claims under s 19A of the Income Tax Act (Cap 134, 2008 Rev Ed) for the Years of Assessment 2011, 2012 and 2013, in respect of capital expenditure on two runways, various taxiways, and aprons, on the basis that they were "plant" within the meaning of s 19A.

[2024] SGHC 281 explained

CHANGI AIRPORT GROUP (SINGAPORE) PTE LTD v COMPTROLLER OF INCOME TAX ([2024] SGHC 281) is a Singapore judgment decided by the High Court (General Division) on 1 November 2024. It is categorised under Revenue Law. It is a recent decision; within this corpus no later judgment has cited it yet. This page summarises what the reported decision covers and links the primary sources — the full judgment, the statutes it cites, and the other cases it engages with — so the decision can be read in context. It is reference information, not legal advice, and it does not state the outcome or any holding beyond what the official judgment records.

What is [2024] SGHC 281 about?

CHANGI AIRPORT GROUP (SINGAPORE) PTE LTD v COMPTROLLER OF INCOME TAX ([2024] SGHC 281) is a High Court (General Division) decision from 2024. Its published catchwords are “Revenue Law — Income taxation — Capital allowance”, which indicate the subject matter the judgment addresses. The full reasoning and orders are in the judgment itself, linked below.

Which legislation does [2024] SGHC 281 consider?

The judgment refers to Income Tax Act (Cap 134) and UK Customs and Inland Revenue Act. The statutes cited are listed in full on this page, each linking to its primary text.

What earlier Singapore cases does [2024] SGHC 281 cite?

Among the in-corpus authorities it refers to are [2024] SGHC 97. The complete list of cases cited, and of later cases that cite this decision, is shown on this page.

Summary

Changi Airport Group (Singapore) Pte Ltd, the licensed operator of Changi Airport, appealed against a decision of the Income Tax Board of Review concerning its claims for capital allowances under section 19A of the Income Tax Act in respect of capital expenditure on two runways, taxiways and aprons. The Comptroller of Income Tax had treated those assets as "structures" rather than "plant" and disallowed the capital allowance claims, and the central issue was whether the assets qualified as "plant". The General Division of the High Court, per Choo Han Teck J, held that the Board's decision was not unreasonable and disclosed no error of law, affirmed the Board's finding, and dismissed the appeal.

What did Changi Airport Group (Singapore) Pte Ltd v Comptroller of Income Tax [2024] SGHC 281 concern?

Decided by Choo Han Teck J, the case concerned capital allowance claims under s 19A of the Income Tax Act (Cap 134) for Years of Assessment 2011 to 2013, over whether two runways, taxiways and aprons at Changi Airport were "plant" within the meaning of s 19A.

Why did Changi Airport Group appeal to the High Court in [2024] SGHC 281?

The appeal (Tribunal Appeal No 4 of 2024) arose from Income Tax Board of Review Appeal Nos 21 to 23 of 2016 and a Grounds of Decision dated 7 June 2024, concerning capital allowances under s 19A of the Income Tax Act for runways, taxiways and aprons.