Contents
  1. ← Reading guide
  2. Exam-day plan
  3. Practice questions
  4. Add back or allow?
  5. Flashcards
  6. Theory bank

Companion to the ATX 2026 Reading Guide

The workbook: practise the 2026 law

No past paper has yet been set under the Nigeria Tax Act 2025, so this page supplies the practice. Eight questions are modelled on the patterns of the last twelve diets, with full answers under the new law. There's also a drill for the examiner's favourite trap, flashcards for every number, and mark-ready answer frames for the theory topics that keep returning.

← Reading guideStart a questionStart the drillFlashcards
Read before you start

These questions are original, written for practice; they are not ICAN questions. Where the 2026 Study Text leaves a method open (for example, how the residue of a pre-2026 asset is spread, or where a cost-price-ratio restriction is absorbed), the answer states its assumption. In the exam, write the same kind of note: it earns credit and protects you if the marker takes a different view.

Before the hall

Exam-day plan

The paper runs 3 hours 15 minutes, including 15 minutes' reading. That leaves 180 writing minutes for 100 marks: 1.8 minutes a mark.

Reading15min
Q1 · 30 marks54min
Section B36min
Section B36min
Section C27min
Section C27min
Use the 15 minutes' reading time
  1. Read every requirement first, then the Section B and C scenarios. Pick your four optional questions now.
  2. Prefer the computations you have drilled: the hydrocarbon tax question in B and the gains question in C have appeared almost every diet.
  3. In Question 1, mark every expense line with A (add back), OK or D (deduct), and note each date's year of assessment and which law applies.
  4. Note any part that asks for theory: those marks are the fastest to earn.
While writing
  1. Start with the question you know best. A confident first answer settles you.
  2. Stop at the time budget. The first 60% of a question's marks takes half the time; the last marks take the rest.
  3. Report or memo heading, introduction, summary table, then appendices. Each carries marks.
  4. One point per mark in theory parts, each starting with a bold key phrase.
  5. If you are stuck on a figure, state an assumption and move on. Later lines can still score.
Company tax order
  1. Basis period and YOA
  2. Adjusted profit (A / OK / D)
  3. Chargeable gains (separate working)
  4. Capital allowances (class, life, transition)
  5. Total profit = assessable + gains − loss − CA
  6. CIT 30%, levy 4% of assessable
  7. Minimum ETR test, credits, WHT
Hydrocarbon tax order
  1. Licence (PML 30% / PPL 15%) and terrain
  2. Revenue at fiscal price × barrels × rate
  3. Allowed costs; list disallowed with reasons
  4. CPR working (A, B, C1, C2, D)
  5. Adjusted → losses (same class) → assessable
  6. Less CA and production allowance
  7. HT on chargeable profit
Gains order
  1. Is it a chargeable asset and disposal? Exempt?
  2. Date of disposal → YOA
  3. Proceeds (or market value)
  4. Less cost or TWDV, plus incidental costs
  5. Part disposal A ÷ (A + B)
  6. Reliefs: replacement, reinvestment, instalments
  7. Add to total profit at 30% (old law: 10% CGT)

Eight questions · full answers

New-law practice questions

Attempt each one on paper under the time budget before opening the answer. Figures are in ₦'000 unless stated.

Q1 · Okeke Packaging LtdSection A style · 30 marks · 54 minutes

Okeke Packaging Ltd is a Nigerian manufacturer with a 31 December year end. For the year ended 31 December 2026 its turnover was ₦3.2 billion, its fixed assets ₦1.4 billion, profit before tax ₦412,500k and EBITDA ₦520,000k.

Charged before PBT₦'000
Depreciation96,400
Impairment of trade investment8,000
Unrealised exchange loss on a USD loan3,600
Realised exchange loss on supplier payments2,200
Penalty for late filing of returns1,500
WHT borne on the landlord's behalf900
Donation to a charitable hospital in Lagos45,000
Donation to a political party2,000
Research and development190,000
Interest to the foreign parent company150,000
Interest to a Nigerian bank40,000
Imported consumables, import duty not paid5,500
Legal costs defending title to factory land2,400
Hearing aids and ramps for disabled staff1,200
Credited before PBT₦'000
Dividend from a Nigerian quoted company (net)13,500
Interest on FGN bonds9,000
Profit on sale of a machine7,000
Unrealised exchange gain2,000

Machine sold: bought January 2023 for 80,000. CITA allowances for 2024–2026 YOA totalled 70,000 (initial 40,000; annual 3 × 10,000). Sold in August 2026 for 32,000.

Other assets: factory building, cost 400,000 in 2022; CITA allowances claimed for 2023–2026 YOA were initial 60,000 and four annual allowances of 34,000. Motor vehicles bought in 2021 for 30,000 were fully relieved under CITA, with ₦10 kept per vehicle. Additions in 2026: plant 250,000 (March); software 40,000 (May); the managing director's car 36,000, used 25% privately; an imported delivery van 20,000 on which import duty has not been paid.

Unrelieved loss brought forward 40,000. WHT credit notes 12,000.

Required
(a) Adjusted profit for the relevant year of assessment. (10 marks)
(b) Capital allowances. (7 marks)
(c) Income tax, development levy and net tax payable. (9 marks)
(d) Comment on the minimum effective tax rate and on the interest not deducted. (4 marks)
Show the model answer

Basis period 1 January – 31 December 2026, so this is the 2027 year of assessment, wholly under the NTA. Turnover above ₦100m means Okeke is not a small company, so the 30% rate applies.

(a) Adjusted profit2027 YOA · ₦'000
Profit before tax412,500
Add back
Depreciation96,400
Impairment (s.21 NTA)8,000
Unrealised exchange loss3,600
Late-filing penalty1,500
WHT borne for the landlord900
Hospital donation above cap: 45,000 − 10% × 412,5003,750
Political party donation (not a qualifying body)2,000
R&D above cap: 190,000 − 5% × 3,200,00030,000
Interest above cap: 190,000 − 30% × 520,00034,000
Expense with import duty unpaid5,500185,650
Deduct
Dividend (franked investment income)13,500
FGN bond interest (exempt)9,000
Book profit on machine (replaced by the gain)7,000
Unrealised exchange gain2,000(31,500)
Adjusted (assessable) profit566,650
No adjustment: realised exchange loss; legal costs defending title (newly allowable under s.20); assistive devices for disabled staff (newly allowable).
Chargeable gain on the machine₦'000
Proceeds32,000
Less TWDV (80,000 − 70,000)(10,000)
Gain22,000
Allowances were claimed, so deduct the TWDV, not cost. The ₦22m includes ₦12m of allowances clawed back plus ₦10m real gain. There is no balancing charge under the NTA, and no allowance this year because the machine was not owned at 31 December 2026.
(b) Capital allowances₦'000
Factory: residue 400,000 − 60,000 − 136,000 = 204,000 ÷ 6 remaining years34,000
Plant 250,000 × 20%50,000
Software 40,000 × 25%10,000
MD's car 36,000 × 25% × 75% business use6,750
Vehicles fully relieved under CITAnil
Imported van, import duty unpaidnil
Total100,750
Factory: class 1 (10%, 10-year life), 4 years already claimed, so 6 remain. Assumption: the residue is spread evenly over those years. Record 1% of each asset's cost as a notional amount.
(c) Tax payable2027 YOA · ₦'000
Assessable profit566,650
Add: chargeable gain22,000
Less: loss b/f(40,000)
Less: capital allowances(100,750)
Total profit447,900
Income tax @ 30%134,370
Development levy @ 4% × 566,65022,666
Less: WHT credit notes(12,000)
Net tax payable145,036
(d) Comments
  • Minimum ETR: turnover of ₦3.2bn is below ₦50bn and there is no group of €750m, so the 15% rule does not apply.
  • Interest: ₦34m above 30% of EBITDA is disallowed for 2027 and carried forward to be deducted, within the same cap, for up to five years (to 2032 YOA). Nigerian subsidiaries of foreign banks and insurers are outside the rule.
Q2 · Ada Foods Ltd: basis periods under s.22–23 NTApart question · 8 marks · 14 minutes

Ada Foods Ltd started trading on 1 June 2026 and prepared accounts to 31 December 2026 and 31 December 2027. It then changed its year end, preparing accounts for six months to 30 June 2028 and for the year to 30 June 2029. It bought plant for ₦70m in June 2026.

Required
(a) Basis periods for the first four years of assessment. (4 marks)
(b) Capital allowance on the plant for the first and third years of assessment. (2 marks)
(c) The company's obligation on changing its accounting date. (2 marks)
Show the model answer
YOABasis periodRule
20271 Jun 2026 – 31 Dec 2026 (7 months)First year: commencement to end of first accounting period (s.22)
20281 Jan 2027 – 31 Dec 2027Preceding year basis
20291 Jan 2028 – 30 Jun 2028 (6 months)Year of change: day after previous basis period to new date (s.23)
20301 Jul 2028 – 30 Jun 2029New accounting date thereafter

(b) Plant is class 2 (20%): ₦14m a year. 2027 YOA has a 7-month basis period: ₦14m × 7/12 = ₦8.17m. 2029 YOA has a 6-month basis period: ₦14m × 6/12 = ₦7m.

(c) Notify the NRS of the change at least 30 days before the usual due date for filing its income tax return. The old CITA comparison (three years, old date vs new date, higher total) no longer applies.

Q3 · Ikeja Delta Energy Ltd: hydrocarbon taxSection B style · 20 marks · 36 minutes

Ikeja Delta Energy Ltd converted its onshore OML to a petroleum mining lease in 2023 under the PIA 2021. For the year ended 31 December 2026 (₦1,500 = $1):

SalesVolumeActual $Fiscal $
Crude oil6.0m bbl6870
Condensate, associated gas1.2m bbl6262
NGL, associated gas0.8m bbl4040
Costs₦m
Royalty paid118,440
Concession rentals600
Host Community Development Trust9,000
NDDC contribution4,000
Environmental Remediation Fund2,500
Production costs420,000
Drilling: first exploration well25,000
Drilling: third appraisal well12,000
Repairs of plant and fixtures8,000
Terminalling6,000
Gas reinjection wells7,500
Stamp duty and State ground rent900
Geological and geophysical data3,000
Other information on deposits1,500
Decommissioning fund (20% in Nigerian escrow)10,000
Gas flaring penalty2,400
Bank charges600
Head office shared costs15,000
Signature bonus on a new block20,000
Depreciation40,000

Qualifying expenditure: plant ₦100,000m (2024); drilling ₦60,000m (2026, including the third appraisal well). Unrecouped capital allowances b/f ₦5,000m. Excess cost b/f under the cost-price ratio ₦8,000m. No losses b/f.

Required
Compute the hydrocarbon tax payable for the relevant year, showing the cost-price-ratio working. (20 marks)
Show the model answer

A PML onshore pays HT at 30%, on an actual year basis: 2026 YOA.

Hydrocarbon tax · 2026 YOA₦ million
Revenue at fiscal price
Crude 6.0m × $70 × 1,500630,000
Condensate 1.2m × $62 × 1,500111,600
NGL 0.8m × $40 × 1,50048,000
Gross revenue789,600
Allowable costs
Exempt from CPR: royalty, rentals, HCDT, NDDC, remediation134,540
Production, first exploration well, repairs, terminalling, reinjection, stamp duty & ground rent, G&G data, escrowed decommissioning480,400
Excess cost b/f8,000
Less: CPR restriction (working)(12,160)
Total allowable deductions(610,780)
Adjusted profit = assessable profit (no loss b/f)178,820
Less: capital allowances (12,000 + 20,000 + 5,000 b/f)(37,000)
Less: production allowance 8.0m bbl × $2.50 × 1,500(30,000)
Chargeable profit111,820
Hydrocarbon tax @ 30%33,546
CPR working (NRS format)₦ million
A: 65% × 789,600513,240
B: costs 134,540 + 480,400 + 8,000 + CA 37,000659,940
C1: exempt costs(134,540)
B − C1525,400
C2: lower of (B − C1) and A513,240
D: allowable C1 + C2647,780
Excess c/f to 2027 (B − D)12,160
Assumption: the restriction is taken from operating costs, so capital allowances are still deducted in full after assessable profit, as in the order the NRS template follows.
Where the marks go
  • Revenue at the fiscal price ($70), not actual ($68).
  • Third appraisal well: not deductible; it is qualifying drilling expenditure, already in the ₦60,000m pool.
  • Disallowed: other information on deposits 1,500; gas flaring penalty 2,400; bank charges 600; head office costs 15,000; signature bonus 20,000; depreciation 40,000.
  • Decommissioning: deductible because at least 15% is in a Nigerian-bank escrow.
  • Production allowance for a converted lease: lower of $2.50 and 20% × $70 ($14), so $2.50, on crude, condensate and NGL.
  • Capital allowances: 20% straight line (2026 drilling 12,000; 2024 plant 20,000).
  • Development levy is not charged on, or deducted for, HT.
Q4 · Zuma Ceramics Ltd: chargeable gainsSection C style · 15 marks · 27 minutes

Zuma Ceramics Ltd (31 December year end) had these transactions in 2026, in ₦ million:

  1. Land bought in 2021 for 90 plus 2 legal and stamp costs. Part sold in April 2026 for 75; agent's fee 1.5. The unsold part is worth 125.
  2. A warehouse (cost 60, TWDV 38) burnt down. Insurance of 50 was received in May 2026 and scrap sold for 2. A replacement was completed in September 2026 for 70.
  3. Shares in a listed Nigerian company, cost 140, sold in March 2026 for 200. In November 2026, 150 was reinvested in shares of another Nigerian company.
  4. A plot bought for 12 was compulsorily acquired by the State in June 2026 for 30. The company had no prior knowledge of the plan.
  5. Investment land, cost 20, sold in July 2026 for 60: 24 on signing, 18 in July 2027 and 18 in July 2028.
Required
(a) The chargeable gains to include in total profit, and the year of assessment. (11 marks)
(b) The capital allowance base for the replacement warehouse. (2 marks)
(c) The tax effect compared with the old 10% CGT. (2 marks)
Show the model answer
(a) Chargeable gains · 2026 accounts → 2027 YOA₦ million
1. Part disposal of land
Proceeds 75 − agent's fee 1.573.5
Cost: 92 × 75 ÷ (75 + 125)(34.5)
Gain39.0
2. Warehouse destroyed
Insurance 50 + scrap 2 = 52 < replacement 70nil
3. Shares
Proceeds of 200 exceed ₦150m, so no threshold exemption. Gain 60 × unreinvested 50 ÷ 20015.0
4. Compulsory acquisition
Not chargeable (gain of 18 exempt)nil
5. Instalments over more than 12 months
Total gain 40; this year's share 40 × 24 ÷ 6016.0
Gains in 2027 YOA total profit70.0
The remaining instalment gains (12 and 12) follow the 2027 and 2028 receipts into later years of assessment. Any instalment later shown to be irrecoverable is adjusted.
(b) Replacement warehouse

Compensation plus scrap (52) is below the replacement cost (70), so there is no gain. The shortfall of 18 is treated as a new qualifying addition. Allowances continue on the old residue of 38. The allowance base is 38 + 18 = 56, not 70, at class 1 (10%).

(c) Tax effect

Gains of 70 at the 30% CIT rate add ₦21m of tax for 2027. Under the old CGT Act the same gains would have cost ₦7m at 10%. Gains are no longer a cheap separate charge, which changes planning around disposals.

Q5 · Kano Leather Ltd: double taxation reliefpart question · 10 marks · 18 minutes

Kano Leather Ltd, a Nigerian company, has a branch in Ghana (no DTA with Nigeria). For the year ended 31 December 2026 (₦ million): Nigerian adjusted profit 300; Ghana branch adjusted profit 100 (after adding back Ghanaian tax). Ghanaian tax paid on the branch profit: 25. Capital allowances: Nigeria 40, branch 10.

Required
(a) Compute the double taxation relief and tax payable under the NTA. (7 marks)
(b) Compare the relief with the old Commonwealth relief under s.44 CITA. (3 marks)
Show the model answer
(a) 2027 YOA₦ million
Assessable profit (300 + 100)400
Less capital allowances (40 + 10)(50)
Total profit350
Income tax @ 30%105
Nigerian tax on branch income: 105 × 90 ÷ 35027
Foreign tax paid25
Credit: lower of 27 and 25(25)
Income tax payable80
Development levy 4% × 40016
Total96
The branch is part of the Nigerian company, so all its profit is taxed here. Foreign tax is never deducted as an expense. Claim the credit within 2 years after the year of assessment. Had Ghanaian tax been 35, the credit would stop at 27.
(b) Old s.44 Commonwealth relief

Ghanaian rate 25 ÷ 100 = 25%, which exceeds half the Nigerian rate (15%), so relief was limited to 15% × branch total profit 90 = 13.5. The NTA credit of 25 relieves the whole foreign tax, because it compares actual taxes rather than half-rates, and it now applies to any country, not just the Commonwealth.

Q6 · Lagos Mega Retail Plc: minimum ETR and dividend taxpart question · 10 marks · 18 minutes

Part A. Lagos Mega Retail Plc (not in a priority sector) had turnover of ₦72bn for 2026. Audited profit before tax was ₦9,000m, including franked dividends of ₦300m and unrealised fair-value gains of ₦200m. Computed CIT is ₦1,500m and development levy ₦280m.

Part B. Its subsidiary, Small Profit Ltd, has total profit of ₦50m for the year but declared a dividend of ₦180m: ₦100m out of retained earnings already taxed and ₦20m out of franked investment income.

Required
(a) Is a top-up due? Show the ETR. What if accelerated allowances cut CIT to ₦650m? (6 marks)
(b) Small Profit Ltd's tax position under s.9 NTA. (4 marks)
Show the model answer
(a) Effective tax rate₦ million
Net income: 9,000 − 300 − 2008,500
Covered taxes: 1,500 + 2801,780
ETR20.9%
If CIT falls to 650
Covered taxes: 650 + 280930
ETR 930 ÷ 8,50010.9%
Top-up: 15% × 8,500 − 930345
Turnover of ₦72bn is above ₦50bn, so the minimum ETR applies. At 20.9% no top-up is due; at 10.9% the company pays ₦345m more. The Study Text method, covered tax ÷ ETR × 15% − covered tax, gives the same figure.
(b) Dividend tax₦ million
Dividend declared180
Less: out of taxed retained earnings(100)
Less: out of franked investment income(20)
Dividend within s.960
Total profit50
Tax: 30% × 60 (dividend exceeds total profit)18
Without the excess the tax would be 30% × 50 = 15. The same exclusions applied under FA 2019; before 2019 the whole ₦180m would have been the tax base.
Q7 · Benue Agro-Fertilizer Ltd: economic development tax creditpart question · 10 marks · 18 minutes

Benue Agro-Fertilizer Ltd manufactures fertilisers, a Tenth Schedule priority sector with a minimum qualifying capital expenditure of ₦20bn. It holds an economic development incentive certificate with production day 1 April 2027. QCE certified up to production day: ₦24bn. Further QCE in priority year 2: ₦6bn. Tax payable before credits (CIT + levy) for priority years 1–5: ₦0.8bn, ₦1.6bn, ₦2.4bn, ₦3.0bn, ₦3.5bn.

Required
(a) The credit available and used each year, and any balance carried forward. (7 marks)
(b) Two conditions that protect the credit. (3 marks)
Show the model answer
Priority yearCredit on ₦24bnCredit on ₦6bnB/fAvailableTaxUsedC/f
11.2——1.20.80.80.4
21.20.30.41.91.61.60.3
31.20.30.31.82.41.8—
41.20.3—1.53.01.5—
51.20.3—1.53.51.5—

Credit is 5% of each QCE a year for five years: ₦24bn → ₦1.2bn a year (₦6.0bn); ₦6bn → ₦0.3bn a year (₦1.5bn). Used in the priority period: ₦7.2bn. The fifth year of credit on the ₦6bn (₦0.3bn) falls after the priority period and may be carried forward for up to five years after it ends, then lapses. Tax actually paid: years 3–5 of ₦0.6bn, ₦1.5bn and ₦2.0bn.

(b) Conditions
  • Separate, auditor-certified books for priority and non-priority business. Without them all income is treated as non-priority and the credit is lost.
  • Evidence of the minimum criteria with each annual return; QCE at or above ₦20bn by production day, or the NRS discountenances the certificate.
  • The credit cannot reduce a 15% minimum ETR top-up, and no other similar incentive may be claimed.
  • The NRS can withdraw credits up to six years after a cancellation (no limit for fraud).
Q8 · Jos Tin & Columbite Ltd: mining companySection C style · 9 marks of computation · 16 minutes

Jos Tin & Columbite Ltd's results for the year ended 31 December 2026 (₦ million): sales of tin concentrate 1,800; royalty paid at the Eighth Schedule rate 135; mining and transport 820; contribution to a mine-closure trust managed by independent trustees 60; further provision for closure, not cash-backed 25; depreciation 140; administration 180 (including a penalty of 3 for late payment of cadastre fees). New QCE in 2026: mining expenditure 500 and plant 300.

Required
Compute the income tax and development levy payable, and say how the 2026 law differs from the old CITA treatment of mining expenditure. (9 marks)
Show the model answer
2027 YOA₦ million
Profit before tax: 1,800 − 135 − 820 − 60 − 25 − 140 − 180440
Add: closure provision not cash-backed25
Add: depreciation140
Add: penalty3
Assessable profit608
Less: capital allowances, mining 500 × 20% + plant 300 × 20%(160)
Total profit448
Income tax @ 30%134.4
Development levy @ 4% × 60824.32
Royalty is deductible (s.64(3) NTA) and is now administered by the NRS. The closure-trust contribution is deductible because it is cash-backed with independent trustees; the bare provision is not.
Old law contrast

Under CITA, mining expenditure took a 95% initial allowance (₦475m in year one) and plant a 50% initial plus 25% annual allowance, subject to the 66⅔% restriction on assessable profit. Under the NTA both are class 2 at 20% straight line with no restriction, so relief is slower but never capped. If the company was granted an NMMA tax holiday before 2026, check whether it is still running.

The examiner's favourite trap

Add back or allow?

One expense or income line at a time. Choose what you would do in an adjusted-profit computation. Company tax lines follow the NTA; hydrocarbon tax lines follow s.68–69 NTA. Your score stays in this browser only.

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Numbers flashcards

Tap the card to reveal the answer. "Again" puts it back in the deck; "Got it" retires it for this round.

Question
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One mark per point

Theory answer bank

Mark-ready point lists for the discussion parts that keep returning. Learn the bold phrase of each point; in the hall, write the phrase and one sentence of explanation.

Asked Nov 2021, May 2025

Back duty audit

  1. Purpose: re-examine past returns where errors, omissions or deliberate understatement are suspected.
  2. Time limit: additional assessments within 6 years; none for fraud or deliberate misstatement (s.36 NTAA).
  3. Process: notification, records examined, tax recomputed and compared with returns filed.
  4. Result: shortfall assessed with penalty and interest at the CBN rate.
  5. Rights: the taxpayer may object (30 days) and appeal to the TAT.
  6. Records: books must be kept at least 6 years, in English or with certified translation.
Asked May 2026

Roles of the Vienna Convention

  1. Codifies interpretation: a uniform approach for courts and tax authorities.
  2. Good faith, ordinary meaning, context, object and purpose (art. 31); supplementary means (art. 32).
  3. Pacta sunt servanda: treaties bind and must be performed in good faith (art. 26).
  4. No internal-law excuse for failing to perform a treaty (art. 27).
  5. Rules for making, amending and terminating treaties.
  6. Consistency and predictability in applying DTAs; supports MAP and arbitration.
Asked Nov 2025

TIWB, cooperative compliance, simultaneous examination

  1. TIWB: OECD–UNDP; experts audit alongside local officials; host country leads; builds capacity, does not replace staff.
  2. Cooperative compliance: trust, transparency and mutual understanding with large taxpayers.
  3. Taxpayer keeps a tax control framework and discloses risks early; authority gives timely certainty.
  4. Benefits: fewer disputes, lower cost.
  5. Simultaneous examination: two or more countries examine one taxpayer at the same time, independently, sharing information.
  6. Challenges: coordination, confidentiality, legal complexity.
Asked Nov 2022, May 2023, Nov 2025

Transfer pricing compliance

  1. Arm's length principle for every controlled transaction.
  2. Declaration form by 30 June: entity, parent, directors, shareholders, structure, connected persons, auditors, consultant, secretary.
  3. Disclosure form by 30 September: income and costs of controlled transactions, summary, method, financials.
  4. TP policy and compliance report: burden of proof on the taxpayer.
  5. Penalties: ₦10m + ₦10k a day; higher of ₦10m or 1%; ₦25k a day for updates.
  6. Disputes: Head of TP Unit within 30 days → Decision Review Panel → TAT; APAs and MAP.
Asked Nov 2021, Nov 2025

BEPS: techniques and OECD strategies

  1. IP and technology licensing through low-tax entities.
  2. Thin capitalisation: debt instead of equity.
  3. Hybrid mismatches: double non-taxation or double deduction.
  4. Entities without substance in preferential regimes.
  5. OECD responses: hybrid rules, CFC rules, interest limits, treaty-abuse rules, PE changes.
  6. TP aligned to value creation; CbCR; MAP; the multilateral instrument.
Asked Nov 2020, May 2025

Tax havens

  1. No or nominal tax on relevant income.
  2. No effective exchange of information.
  3. Lack of transparency.
  4. No substantial activity required.
  5. Counter-measures: CFC rules, TP and thin cap rules, exit charges.
  6. Automatic exchange (CRS, FATCA), blacklists, defensive WHT, substance tests.
Asked Nov 2022, May 2025

Mergers and reorganisations

  1. Merger: no commencement or cessation; no gain; assets at residue.
  2. Unused allowances, losses and WHT credits pass to the survivor.
  3. Sale causing cessation: allowances and losses lost; CA on sale value.
  4. No VAT on transfers in a restructuring.
  5. Related parties: related 1 year before; no disposal within 1 year after; breach revokes.
  6. Tax authority consent and clearance before completion.
Asked Nov 2023, May 2024

National Tax Policy

  1. Features: equity and fairness; simplicity, certainty and clarity; convenience; low compliance cost; low administration cost; flexibility; sustainability.
  2. Government: review laws; quarterly revenue data; funding and autonomy; 3–6 month transition.
  3. Taxpayer: civic duty; right to information, objection, fair appeal, accredited agent.
  4. Revenue agencies: customer focus, cooperation, timely audits, education, anti-corruption.
  5. Professionals: code of conduct; no aiding evasion; promote compliance.
Asked May 2024

NEITI

  1. Vision: an accountable, effective, well-resourced, result-oriented NEITI.
  2. Mission: transparency, accountability, due process and zero tolerance for corruption in the extractive industries.
  3. Due process and transparency in payments to government.
  4. Accountability in revenue receipts.
  5. Eliminate corruption in determining, paying, receiving and posting revenue.
  6. Conformity with EITI principles.
Asked Nov 2020, Nov 2025

Objections and appeals (NTAA)

  1. Written objection within 30 days of service.
  2. Contents: issues and amounts, amendment sought, justification, profit and tax admitted.
  3. Authority responds within 90 days or the objection is upheld.
  4. Appeal to the TAT within 30 days; grounds as in the objection.
  5. Federal High Court on points of law within 30 days; then Court of Appeal and Supreme Court.
  6. ADR and the Tax Ombud as alternatives.
Expected under the 2026 syllabus

Economic development incentive certificate

  1. Apply to the Secretary of NIPC with capital commitment, QCE plans, production date, products, capital structure, ownership.
  2. Fee 0.1% of QCE, maximum ₦5m.
  3. NIPC → Minister → President approves.
  4. Production day certified by the Industrial Inspectorate within a month.
  5. NRS certifies QCE; below the sector minimum, the certificate is discountenanced.
  6. Credit 5% a year for 5 years; separate books; cannot reduce the 15% top-up.
Asked May 2025, Nov 2025

Mining law points

  1. Possession: own title area, a permit to possess or purchase, or an authorised agent (s.93).
  2. Purchase only with a licence (s.94); small-scale output to licensed buying centres (s.95).
  3. Fees: annual service fee; 30 days' default notice, then revocation.
  4. Land: mining has priority and is an overriding public interest; the Governor revokes occupancy rights within 60 days.
  5. Royalty deductible, administered by the NRS.
  6. Closure fund contributions deductible if cash-backed with independent trustees.
Asked May 2026

ESG in the extractive industries

  1. Fines under the Climate Change Act 2021 and regulators' directives.
  2. Litigation and regulatory audits.
  3. Loss of operating licences.
  4. Reputational damage and loss of investor trust.
  5. Supply chain and operational disruption.
  6. Redress through ADR as well as the courts.
Asked Nov 2023, May 2024, May 2026

Tax practice: legal duties and risks

  1. ICAN code: no business that impairs integrity, objectivity or reputation.
  2. Accreditation as a tax practitioner when acting for reward.
  3. IESBA principles: integrity, objectivity, competence and due care, confidentiality, professional behaviour.
  4. Risks: lack of expertise, inattention, poor documentation, unpredictable income.
  5. Mitigation: work within competence, review, engagement letters, insurance, CPD.
  6. Safeguards: profession, firm and engagement level.