Nigeria: Tax Authorities

Intra-group financing arrangement, particularly interest-bearing loan arrangements, have long been one of the foremost tax planning strategies adopted by multinational enterprises to shift profits from one jurisdiction to another. As a result, tax authorities globally tend to scrutinize these arrangements under transfer pricing rules to ensure that the terms of these transactions are at arm’s length.

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.

You may have heard about the new tax reform Acts passed by the National Assembly and signed into law by His Excellency, President Bola Ahmed Tinubu GCFR, in June 2025. These reforms come in four key pieces of legislation: the Nigeria Tax Act, the Nigeria Tax Administration Act, the Joint Revenue Board of Nigeria (Establishment) Act, and the Nigeria Revenue Service (Establishment) Act. Taken together, these pieces of legislation represent the most significant overhaul of Nigeria's tax framework in decades

The question of whether Value Added Tax (VAT) should be remitted on cash or accrual basis has puzzled some taxpayers over the years. This uncertainty persisted, even with the amendments made to the VAT Act (VATA) via various legislations.

Upon coming into force on 1st January 2026, Nigerians and foreign nationals with business interest in Nigeria have been seeking tax experts' opinion on a number of emerging issues in the new...

Nigeria's tax system is undergoing one of its most comprehensive reforms in decades. The Nigeria Tax Administration Act 2025 ("NTAA" or the "Act") represents a major step toward a more efficient, transparent, and technology-driven tax administration.

In an article titled, "Banks as Collecting Agents for FIRS – A Conundrum", I discussed issues arising from the Federal Inland Revenue Service (FIRS)'s recent tax substitution directives...

Understanding VAT has become vital for digital businesses operating in Nigeria.

Fund repatriation plays a vital role in shaping a country's investment climate and broader economic health. For many nations, especially those reliant on foreign direct investment...