Queenstown Airport Corporation Ltd v Commissioner of Inland Revenue - [2017] 2 NZLR 811

Revenue — Income tax — Runway end safety area (RESA) constructed to comply with international standard for international flights — Whether depreciation deductions could be claimed for tax purposes — Whether RESA exception to general rule that land not depreciable property — Whether RESA could be defined as airport runway — Whether RESA hardstanding — Whether RESA might reasonably be expected to decline in value while in use or available for use — “Depreciable property” — “Airport runway” — “Hardstanding” — Civil Aviation Rules, r 139.

Statutes — Interpretation — Consideration of text and purpose — Ordinary meanings — RESA constructed to comply with international standard for international flights — Whether depreciation deductions could be claimed for tax purposes — Whether RESA exception to general rule that land not depreciable property — Whether RESA could be defined as airport runway — Whether RESA hardstanding — Whether RESA might reasonably be expected to decline in value while in use or available for use — “Depreciable property” — “Airport runway” — “Hardstanding” — Income Tax Act 2007, ss EE 6, EE 7, sch 13.