Salient Points About Tax Assessments in Nigeria: BOJ, NORA Etc.

Abstract

Tax assessment in Nigeria is governed by the various tax statutes. Caselaw demystifies and shapes these statutes so that they are easier to understand and implement. In this review, using Nigerian tax legislations and caselaw, I examine the Nigerian tax assessment regime under the following headings:

The validity of best-of-judgment assessments.

What amounts to a proper notice served on the taxpayer?

What happens when the tax authority fails to serve a notice of refusal to amend (NORA) a tax assessment?

Under what circumstances must, or should, tax authorities refund excesses?

What makes an assessment “final and conclusive”?

The Federal Inland Revenue Service (Establishment) Act (FIRS Act) provides for some of the issues highlighted above. Others are covered by the various tax laws. I will now consider them.