From Assessment to Adjudication – Practical Guidance on Tax Objections, Appeals and Resolution Procedures
Nigeria’s 2025 tax reform framework represents one of the most extensive overhauls of the country’s fiscal and revenue administration architecture in decades. The reforms introduced through the Nigeria Tax Act 2025, the Nigeria Tax Administration Act 2025, the Nigeria Revenue Service (Establishment) Act 2025, and the Joint Revenue Board of Nigeria (Establishment) Act 2025 have fundamentally reshaped tax administration, compliance obligations, dispute resolution mechanisms, and taxpayer engagement processes.
With increased digitalisation, expanded audit powers, integrated tax administration, and stronger enforcement mechanisms, tax controversies are expected to rise significantly. Consequently, taxpayers, tax advisers, legal practitioners, and corporate finance teams must understand the procedural framework governing objections, appeals, settlements, and adjudication under the new regime.
This article provides practical guidance on navigating tax disputes under Nigeria’s 2025 tax laws — from the issuance of assessments to final adjudication before the Tax Appeal Tribunal and the courts.
1. Understanding Tax Controversies under the 2025 Tax Regime
A tax controversy generally arises where a taxpayer disagrees with the position of a tax authority concerning:
- Additional tax assessments;
- Transfer pricing adjustments;
- VAT liabilities;
- Withholding tax exposures;
- Personal income tax determinations;
- Penalties and interest;
- Tax audits and investigations;
- Interpretation of tax statutes;
- Alleged non-compliance or under-reporting.
The Nigeria Tax Administration Act 2025 (“NTAA”) creates a more centralised and technology-driven compliance environment. Tax authorities now possess enhanced powers to assess, investigate, demand records, and enforce compliance. These developments make proactive controversy management essential for businesses operating in Nigeria.