In a ruling with significant procedural implications for property tax appeals, the Valuation Review Board (VRB) has dismissed Shaw Towers Realty (Pte.) Limited’s application for leave to amend its notice of appeal and proposed annual values ([2025] SGVRB 1).
The appellant sought to revise its originally filed annual values downward, citing a new ground of appeal: the residual method of valuation, referenced in subsequent 2024 guidance from the Singapore Institute of Surveyors and Valuers (SISV). The Chief Assessor objected.
The Board dismissed the application, providing critical clarifications for practitioners:
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Regulatory Gap: The relevant procedure regulation (Reg 7 of the Valuation Review Board (Appeals Procedure) Regulations) is silent on amending the disputed annual value itself, even if new grounds might be considered.
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“New Ground” Definition: The Board found the residual method is not a new valuation technique; thus, reliance on updated SISV circulars did not constitute a novel ground of appeal.
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Distinction Between Values and Grounds: The appellant incorrectly conflated proposing lower annual values with introducing new appeal grounds.
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Non-Retroactivity of New Rules: The updated Property Tax (Appeals Procedure for Valuation Review Board) Regulations 2025, which prescribe amendment procedures, were not applicable as the appeal was lodged prior to 1 April 2025.
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Conduct Scrutiny: The Board noted that appointing two expert witnesses to opine on different methods suggested “forum shopping” for a favourable valuation outcome.
Practical Impact:
This decision underscores the critical importance of finalising valuation positions and grounds before filing a notice of appeal. Reliance on potential future professional guidance or alternative valuation methods post-filing is risky and may not justify amendment.
The ruling highlights the VRB’s strict interpretation of procedural boundaries and its scrutiny of appellant conduct. Professionals must ensure appeals are meticulously prepared at inception, as flexibility to amend fundamental figures post-submission is severely limited.
Source: Shaw Towers Realty (Pte.) Limited v Chief Assessor [2025] SGVRB 1, 18 December 2025