Nigeria's Tax Appeal Tribunal issued a decision on 5 July 2019 concerning whether dividends distributed out of a prior year's post-tax profits are subject to the so-called excess dividends tax when distributed in a later year in which there was no profit declared. The excess dividends tax is provided for in Section 19 of the Companies Income Tax Act, which essentially provides that dividend distributions in excess of total (assessable) profit are treated as profits subject to tax at the standard rate (30%). The case involved a taxpayer that had no profit for the 2014 year of assessment, but distributed...