Nigeria's tax system has undergone its most significant reform in decades. The tax reform Acts of 2025, including the Nigeria Tax Act and the Nigeria Tax Administration Act, consolidated many tax laws and reorganised tax administration, with the Nigeria Revenue Service replacing the Federal Inland Revenue Service at federal level. State tax authorities, such as the Lagos State Internal Revenue Service and the FCT Internal Revenue Service, continue to administer state-level taxes.
Change brings uncertainty, and disputes over interpretation, transitional provisions and assessments are inevitable. We help taxpayers manage these disputes from the first query to final appeal.
Disputes we handle
- Tax audits and investigations, and responses to information requests
- Best-of-judgment and additional assessments
- Disputes over value added tax, withholding tax and companies income tax
- Transfer pricing adjustments
- Personal income tax and PAYE disputes with state tax authorities
- Penalties and interest for late filing or payment
- Disputes over tax incentives and exemptions
The dispute process
Most tax disputes begin with a notice of assessment. The taxpayer must generally file a valid objection within the prescribed period, setting out the grounds clearly. If the objection is refused, the taxpayer can appeal to the Tax Appeal Tribunal, and further appeals lie to the Federal High Court and beyond. Strict time limits apply at each stage, and missing them can make an assessment final.
The reforms also created new avenues, including the Office of the Tax Ombud, which handles certain complaints about tax administration. We advise on which route best suits each dispute.
How we assist
- Reviewing assessments and identifying errors in law, fact and computation
- Preparing objections and supporting documentation
- Negotiating with tax authorities to resolve disputes without litigation
- Representing clients before the Tax Appeal Tribunal and the courts
- Seeking orders to restrain unlawful enforcement measures, such as account freezing or premises sealing
Disputes are best avoided through sound planning. Our tax advisory and compliance team helps clients align with the new rules before issues arise.
