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Nigeria: Tax filing obligations for companies in exploratory stage of petroleum operations (tribunal decision)

Late-filing penalties under the Petroleum Profits Tax Act (PPTA) apply even during the exploratory phase.

april 7, 2026

The Tax Appeal Tribunal, Lagos Zone, on February 20, 2026, dismissed a taxpayer’s appeal and upheld the imposition of late‑filing penalties under the Petroleum Profits Tax Act (PPTA).

The tribunal held that companies engaged in petroleum operations, including at the exploratory stage, are required to file petroleum profits tax returns under section 30 of the PPTA, as amended by the Finance Act 2023. It confirmed that failure to file PPT returns draws penalties, regardless of prior filing practice under the Companies Income Tax Act or production sharing contract arrangements.


For more information, contact a KPMG tax professional in Nigeria:

Damilola Ojebode| damilola.ojebode@ng.kpmg.com

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