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

[2025] SGHC(A) 20 High Court (Appellate Division) 25 September 2025 • AD/CA 93/2024 • 29 min read
10 cases cited (6 SG, 4 foreign)

Catchwords

Revenue Law — Income taxation — Appeals — Whether expenditure eligible for capital allowance — Whether asset considered “plant” or structure

Practice Areas

Revenue Law

Judges (3)

Debbie Ong Siew Ling Coram See Kee Oon Delivered Woo Bih Li Coram

Counsel (11)

Allen & Gledhill LLP Firm Inland Revenue Authority of Singapore (Law Division) Firm Han Junwei Counsel Appellant Jasper Wong Chun Yin Counsel Respondent Jonathan Kenric Trachsel Counsel Appellant Kenneth Wang Ye Counsel Appellant Koh Swee Huang Flora (Xu Ruifang) Counsel Respondent Lee Long Jin Bjorn Counsel Respondent Li Yourui Charles Counsel Respondent Phua Lye Huat Stephen Counsel Appellant Quek Hui Ling Counsel Respondent

Parties (2)

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

Case Significance

[2025] SGHC(A) 20 is a High Court (Appellate Division) decision dated 25 September 2025 concerning Revenue Law, specifically addressing income taxation. The judgment was delivered by See Kee Oon, with Debbie Ong Siew Ling and Woo Bih Li on the coram. The case was brought by Changi Airport Group (Singapore) Pte Ltd (appellant) against Comptroller of Income Tax (respondent). Legal representation was provided by Allen & Gledhill LLP and Inland Revenue Authority of Singapore (Law Division). The judgment cites 10 cases (6 Singapore, 4 foreign) and references 2 statutory provisions, including the Income Tax Act and the Supreme Court of Judicature Act.

Summary

Changi Airport Group appealed against the decision that its runways, taxiways and aprons did not qualify as 'plant' eligible for accelerated capital allowances of over $272 million under the Income Tax Act. The Appellate Division dismissed the appeal, agreeing that the airport infrastructure constituted structures rather than plant, and ordered costs of $50,000.

What was decided in [2025] SGHC(A) 20?

[2025] SGHC(A) 20 (CHANGI AIRPORT GROUP (SINGAPORE) PTE LTD v COMPTROLLER OF INCOME TAX) is a High Court (Appellate Division) decision from 25 September 2025 addressing Revenue Law, specifically income taxation. The judgment was delivered by See Kee Oon.

Who were the parties in CHANGI AIRPORT GROUP (SINGAPORE) PTE LTD v COMPTROLLER OF INCOME TAX?

The appellant in [2025] SGHC(A) 20 was Changi Airport Group (Singapore) Pte Ltd, and the respondent was Comptroller of Income Tax. Legal representation included Inland Revenue Authority of Singapore (Law Division) and Allen & Gledhill LLP. The case was decided on 25 September 2025 in the High Court (Appellate Division).

Which judge decided [2025] SGHC(A) 20?

[2025] SGHC(A) 20 was delivered by See Kee Oon in the High Court (Appellate Division) on 25 September 2025. Debbie Ong Siew Ling and Woo Bih Li also sat on the coram. The case concerned Revenue Law.

What cases and statutes does [2025] SGHC(A) 20 cite?

[2025] SGHC(A) 20 cites 10 prior decisions, including 4 from foreign jurisdictions. It references Income Tax Act, Supreme Court of Judicature Act.

Statutes Cited

Income Tax Act (Cap 134)
s 19A
Supreme Court of Judicature Act (Cap 322)
s 41(1)

Cases Cited (10)

SG (1)
[2024] SGHC 97
SLR (5)
[2006] 1 SLR(R) 484 [2011] 1 SLR 1044 [2014] 2 SLR 847 [2023] 5 SLR 1099 [2025] 4 SLR 862
UK (4)
[1914] 3 KB 406 [1940] AC 774 [1956] AC 14 [1969] 1 WLR 675

Judgment

Read the full judgment on the official Singapore Courts portal.

Read on eLitigation

Source: eLitigation ([2025] SGHC(A) 20)