Nigeria's Tax Appeal Tribunal has reportedly issued a decision regarding the interpretation of Nigeria's tax treaties considering the OECD Model Tax Convention Commentary. The case concerned the interpretation of Article 8 (Shipping and Air Transport) of the 1990 income and capital tax treaty between Nigeria and France as it applies to non-freight income of a taxpayer, including demurrage, cleaning fees, container sales, shipping line agency commissions, etc. The taxpayer claimed that the exemption provided under Article 8 of the treaty should cover non-freight income, considering the interpretation provided by the 2008 OECD Commentary, which provides that the profits of a...