Drew & Napier Deputy Chief Officer Ong Sim Ho comments on Changi Airport tax ruling in Lianhe Zaobao

15 Oct 2025

Deputy Chief Executive Officer Ong Sim Ho was quoted in Lianhe Zaobao regarding the Appellate Division’s decision involving Changi Airport Group and the Comptroller of Income Tax, concerning whether the airport’s runways, taxiways, and aprons qualify for capital allowances.

The Court held that these facilities constitute building structures rather than plant and are therefore ineligible for accelerated capital deductions. The ruling affirms the principle that only machinery and equipment, and not land or structural works, qualify for capital allowances under Singapore law.
 
Sim Ho noted that earlier deductions are more advantageous under the financial concept of present value, which explains why businesses often seek to accelerate capital allowances to improve cash flow. He observed that while the legal distinction between plant and building structures is well established, grey areas remain in large-scale infrastructure cases, where advances in construction technology may blur the boundary between the two.
 
He further highlighted that while the Court’s decision upholds tax stability, policy reform lies with Parliament and not the judiciary, and suggested that businesses should engage in tax policy advocacy early in project planning, especially as infrastructure technologies evolve faster than the tax framework.
 
You may read the full article here.