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


The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.