This edition features key decided tax cases (which became publicly available in 2019) that have greatly helped in addressing tax disputes between taxpayers and the Revenue. It also contains key pronouncements from tax administrators and regulatory agencies. In addition, the journal includes a compilation of select thought leadership articles on tax, TP, regulatory and compensation and benefits issues authored by KPMG Nigeria subject-matter specialists in 2019. This year’s edition also features articles by external tax and legal practitioners who expressed their views on topical tax and regulatory issues.

Tax remained a front-burner issue all through the year 2019, owing to the numerous developments in the tax space. Some of these include:

• controversies surrounding the FIRS’ exercise of its power of substitution to “freeze” bank accounts of alleged tax defaulters;
• the enforcement of the provisions of the Income Tax (TP) Regulations and CbCR Regulations issued by the FIRS in 2018, especially with respect to the imposition of stiff penalties for non-filing or late filing of relevant returns/notifications;
• the issuance of the Common Reporting Standard Regulations, which will give effect to the automatic exchange of information in Nigeria;
• TAT decisions on numerous tax issues;
• the change in the leadership of the FIRS upon the expiration of the four-year tenure of its erstwhile Executive Chairman; and
• the presentation of the 2020 Budget proposals together with an Executive Finance Bill, by His Excellency, President Muhammadu Buhari to a joint sitting of the National Assembly.

The curtain for 2019 was drawn with the signing into law of the 2020 Appropriation Bill, with a revenue target of N8.42 trillion1; and the passage of the Finance Bill, 2019 by the National Assembly.

The Finance Bill was signed into law by the President as Finance Act, 2019 (“Finance Act” or “the Act”) on 13 January 2020. The enactment of the Act is a significant milestone for Nigeria, as it marks the first significant amendment of Nigeria’s corporate and transaction tax legislation in almost thirteen (13) years. Our expectation is that the FGN would continue the practice of submitting a Finance Bill along with the Budget to the National Assembly in subsequent years, in line with global best practice.

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