According to recent reports, the Tax Appeal Tribunal in Lagos, Nigeria has issued a decision regarding the constitutionality of the Income Tax (Country-by-Country Reporting) Regulations 2018. The case concerned a Nigerian company that was issued notices of administrative penalties by the Federal Inland Revenue Service (FIRS) for failing to file CbC notifications for 2019 and 2020 as required by the CbC Regulations. As specified in the regulations, the penalties for failing to submit notifications include an initial penalty of NGN 5 million, plus a penalty of NGN 10,000 per day of delay. The company appealed the notices, arguing that the...