The firm has a highly competent tax practice team to address Clients’ taxation challenges. One of our partners- Alewo F. Etuk, is a Chartered Tax Practitioner duly licensed by the Chartered Institute of Taxation (CITN).  The firm is abreast of current and best practices in corporate tax policies, taxation of oil and gas companies based on three principal Acts that provide for the taxation of companies’ operating profits in the oil and gas industry in Nigeria – Petroleum Profits Tax Act (PPTA), Deep offshore and Inland Basin Production Sharing Contracts Act (DOIB PSC) and the Companies Income Tax Act (CITA).

The firm is well positioned to provide tax advisory and management services to Oil and Gas and other exploratory operations, in respect of tax computation, tenure of oil prospecting/mining licenses, petroleum profits tax, investment tax credit and investment allowance, royalties on deep offshore production sharing contracts, computation of petroleum profits tax under DOIB PSC, non-allowable deductions on allocation of royalty oil, cost oil, tax oil and profit oil relevant to tax chargeable on petroleum operations. As chartered tax practitioners, we file clients’ returns, on estimated and final tax liabilities to the Federal Inland Revenue Service (FIRS), a minimum of two months after the commencement of each accounting period.  We also guide our clients on how to claim the benefits of statutory provisions on capital allowance and petroleum investment allowance rates. Our tax advisory and tax representation services work with clients on tax policies and regulations related to contracts, and license regimes applicable to our clients’ businesses.

The firm represents clients at tax tribunals and tax appeals in the event of tax objections. We also work with our clients during the tax objection phase; and with our clients’ consent, engage in lawful negotiation and mediation with the tax authorities to resolve objections and issues raised.

In the event of failure to amicably resolve tax disputes and upon the receipt of the Notice of Tax Refusal to amend (NOTRA), and a Notice of the Revised Assessment (NRA), a tax appeals process is commenced within 30 days of receipt of the notices or 60 days for our Oil and Gas companies, if valid reasons exist for the delay in filing the appeals.

The firm offers sound professional advice to its clients in this regard, as each situation is scrutinized, and the best approach advised by us based on the peculiarity of each case. However, we are careful to guide our clients and steer them from incurring needless penalties for filing appeals on frivolous grounds. We assess the claims and likelihood of success for each tax appeal filed by our clients and advise our clients appropriately. Some of the grounds of objection we have validly raised on behalf of our clients include issues of excessive taxation and double taxation. As chartered tax practitioners with legal expertise, we represent our clients in tax related proceedings at tax tribunals, the Federal High Court, Court of Appeal and Supreme Court, if needs be, in disputes arising from all Nigerian tax statutes, with the exception of the Education Tax Act which is omitted in the FIRS Act 2007.

Clients have thus successfully challenged the refusal of tax authorities to allow utilizing reserve additional bonuses to offset petroleum profits. Clients have also successfully challenged the tax authorities’ position on when an assessment is considered final and conclusive.