Nigeria's principal corporate tax legislation, the Companies Income Tax Act 1961, stipulates as a basis for the taxation of a nonresident company deriving income in Nigeria, what it terms a “single contract.” This, according to the statute, entails a contract that embodies the activities of...

The interaction between tax administration, discretion and legitimate expectation has been widely explored. However, the subject has traditionally been approached from the perspective of legality and deeply focused, normatively, on how courts adjudicate cases bordering on the frustration of...

There is a global rush to tax the digital economy. As at June 2020, more than a hundred countries have formulated or adopted unilateral measures towards that objective. Most of these domestic measures are in the incubator, as countries concurrently explore multilateral options to find a...

Few issues have challenged tax policymakers and commentators as much as digital taxation has in recent years. Ongoing efforts to reconstruct the rules of international tax to “properly” govern the taxation of the global digital economy have evoked some important tax and trade related...

The viability of our international tax system hinges on two things: (1) safeguarding the effective flow of international activities and (2) ensuring that countries can adequately collect tax on the income derived from those activities. Each of these fundamentals relies on a defensible/fair...

Nigeria has a long history of legal conflict on fiscal federalism. One dimension borders on who has the power to tax the consumption of goods and services. Although the Nigerian Constitution prescribes how taxing powers are to be exercised between the federal government and the federating units,...