Article
Retrospective Legislation, Proration Of Tax Rates, And The Fragmentation Of Accounting Periods: Revisiting The Federal High Court Decision In Shell v. FIRS
The decision of the Federal High Court ("the Court") in Shell Petroleum Development Company of
Nigeria Limited v. Federal Inland Revenue Service (FIRS)1 has brought renewed attention to
fundamental principles of Nigerian tax law, particularly regarding the proration of tax rates within an
accounting year and the retrospective application of tax legislation.
KPMG Nigeria