The increased presence of Multinational Enterprises (MNEs) across various jurisdictions has, among other things, created the need to centralise certain functions within the MNE Group. Many MNEs have adopted a shared services arrangement to centrally provide certain business support services to members of the group.
Background On 28 May 2021, the Tax Appeal Tribunal (TAT) South-South Zone, sitting in Benin, delivered a judgment in a matter between Ecobank Nig. Ltd (“the Bank”) v Delta State Board of Internal Revenue (“the Revenue”). The matter bordered on the legality or otherwise of
Background Transfer Pricing (TP) in Nigeria is governed by the Income Tax (Transfer Pricing) Regulations, 2018 (TPR). The TPR provides that Related Party Transactions (RPTs) should be conducted in line with the arm’s length principle and provides compliance obligations for taxpayers. The annual compliance obligations
Background The Companies and Allied Matters Act 2020 (CAMA 2020 or the Act) was signed into law and gazetted with a commencement date of 7 August 2020. The Act, which repeals the 1990 Company Act, introduces wide-range of changes to Nigeria’s business environment. It is
On 24 January 2021, President Muhammadu Buhari ordered the Federal Inland Revenue Service (FIRS) to collect the statutory levy applicable under the National Agency for Science and Engineering Infrastructure (NASENI) Act. The Federal Government of Nigeria established the Agency (NASENI) in 1992 with the primary
Background It is important to recall that the Finance Act (FA) 2020 introduced an amendment to the Federal Inland Revenue Service Establishment Act (FIRSEA), empowering the Service to deploy proprietary technology to automate the tax administration process in Nigeria. The FIRS however, must give 30
Download the PDF for COVID-19 and the imperative for SMEs operational resilience. “It is not the strongest of the species that survives, nor the most intelligent, but rather the one most adaptable to change” -Charles Darwin The material (dated 13th July 2020) was prepared by
Background Tourist Company of Nigeria Plc (TCN or the Appellant) engages in the gaming and hospitality business including the operation of a casino, in Nigeria. The FIRS assessed TCN to ₦88m in unpaid VAT (inclusive of penalties and interests) for the 2016 year of assessment
Background Section 30(1)(b) of the Companies Income Tax Act (CITA) grants FIRS the discretion to assess foreign companies to tax on a reasonable percentage of their turnover where it appears to FIRS that the company either has no assessable profits or has assessable profits that
Background On 30 November 2020, the Tax Appeal Tribunal (TAT or the Tribunal) sitting in Lagos decided in the case of Tetra Pak West Africa Limited (Tetra Pak or the Appellant) and Federal Inland Revenue Service (FIRS or the Respondent) that sales in the ordinary