Nigeria: Country-by-country reporting rules not validly adopted and thus unenforceable (Tax Appeal Tribunal decision)
A Tax Appeal Tribunal decision concerning country-by-country reporting rules
A Tax Appeal Tribunal decision concerning country-by-country reporting rules
The Tax Appeal Tribunal Lagos Zone held that the country-by-country (CbC) regulations, 2018 were not adopted by a legally constituted Board of the Federal Inland Revenue Service (FIRS) in accordance with the provisions of Section 61 of the FIRS (Establishment) Act, 2007 (FIRSEA), rendering them illegal, unconstitutional, and void.
The administrative penalties for non-compliance with the CbC rules thus are invalid and unenforceable.
Read a September 2023 report [PDF 1.2 MB] prepared by the KPMG member firm in Nigeria
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