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Nigeria: Taxpayer’s right to appeal when assessment has been paid

Nigeria: Taxpayer’s right to appeal

The Tax Appeal Tribunal (TAT) sitting in Lagos, on 22 July 2019 issued a decision in a case concerning the taxpayer’s right to appeal when there has been a payment of the tax assessment. The appellate tribunal held that payment of the tax assessment does not extinguish a taxpayer’s right to appeal against the assessment.


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The appellate tribunal resolved this procedural question. However, the substantive issue on appeal—whether Section 19 of Companies Income Tax Act (CITA) applies when a company pays dividends out of franked investment income under Section 80(3) and other investment incomes and that are statutorily exempt from tax—is still pending for determination by the tribunal.

Read a July 2019 report [PDF 127 KB] prepared by the KPMG member firm in Nigeria

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