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Nigeria Tax Appeal Tribunal judgment partially voids Income Tax Country-by-Country Reporting Regulations 2018

12 September 2023

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Tax Alerts, Information Reporting, Legislation & Policy, National/Federal Taxation, Treaties

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Nigeria

The Tax Appeal Tribunal of Nigeria (TAT) has ruled that the Income Tax Country-by-Country Reporting (CbCR) Regulations, 2018 were not made by a legally constituted and properly composed Board of the Federal Inland Revenue Service (FIRS), as required by the governing act. Therefore, to the extent of their inconsistencies, the CbCR Regulations 2018 are rendered null and void.The TAT further upheld that penalty imposed on a defaulting entity must be in tandem with the relevant provisions of the principal legislation. Executive summaryOn 17 August 2023, the Lagos zone of the Tax Appeal Tribunal of Nigeria (TAT) ruled in favor of...