Tax Disputes
We challenge unlawful tax assessments and represent taxpayers at every tribunal level.
Assessment objection windows are short and non-extendable. If you have received a tax assessment you believe is incorrect, contact us before the objection deadline.
No institution — government agency, revenue authority, or public official — is above the law. Tax disputes in Nigeria are complex, time-sensitive, and carry significant consequences if handled incorrectly. Assessment objection windows are short. Procedural errors at the Tax Appeals Tribunal level can affect outcomes on appeal. And most revenue authority assessments are open to challenge on both technical and substantive grounds.
The firm challenges unlawful tax assessments, enforces compliance obligations on revenue authorities, and pursues fundamental rights violations arising from improper revenue agency conduct. The practice covers FIRS income tax, VAT, withholding tax, and transfer pricing matters at federal level, and State Internal Revenue Service assessments at state level.
For businesses that are not yet in dispute, pre-dispute advisory — structuring transactions to minimise tax exposure within the law, ensuring documentation is in order, and understanding the basis of assessments before objecting — is consistently more valuable than reactive litigation. The firm offers both.
Tax proceedings that escalate to the Federal High Court and beyond require advocacy at a level that carries weight with the judiciary. The SAN designation brings institutional credibility that affects how contested tax matters are received at the highest court levels. For large assessments and matters of principle, the quality of senior representation is a material variable.
Services Within This Practice Area
Assessment Objections
Formal objections to FIRS and State IRS assessments within the statutory objection period. Grounds: jurisdiction, computation, applicable law.
Tax Appeals Tribunal
Full representation before the Tax Appeals Tribunal — preparation, filing, hearing, and post-hearing submissions.
Federal High Court Tax Proceedings
Appeal from the TAT to the Federal High Court and above. Judicial review of improper regulatory conduct.
VAT & Withholding Tax Disputes
Challenges to VAT assessments, withholding tax demands, and the basis on which deductions have been computed.
Transfer Pricing
Transfer pricing documentation, compliance advisory for international group structures, and challenge of FIRS transfer pricing adjustments.
Revenue Authority Enforcement Defence
Where FIRS or state revenue authorities have acted improperly: mandamus applications, judicial review, and constitutional challenges.
Selected Outcomes
All matters anonymised in accordance with professional confidentiality obligations.
Tax Appeals Tribunal
FIRS income tax assessment — ₦120M demand
Assessment reduced by 68% following challenge on computational grounds and jurisdictional objection.
Federal High Court
VAT enforcement action — manufacturing sector
Enforcement action stayed pending appeal. Settlement negotiated at fraction of original demand.
Tax Appeals Tribunal
State IRS assessment — personal income tax
Assessment set aside in full. Revenue authority ordered to reassess on correct basis.
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