Practice areas/Assessments, tribunals, structuring
04 Taxation
Tax reviews, negotiations and assessment disputes, with a record of successfully contesting enforcement actions.
The practice
What instructing us on taxation looks like.
We contest assessments that other advisers recommend settling. The practice combines technical tax analysis with tribunal advocacy, from the objection letter through the Tax Appeal Tribunal and onwards on appeal.
Where the exposure has not yet crystallised, the same team reviews structures, group charges and transaction pricing so that the assessment never arrives in the first place.
Scope of work
- FIRS and state revenue assessment disputes
- Tax Appeal Tribunal advocacy and appeals
- Transaction and group structuring reviews
- Transfer pricing and withholding questions
- Voluntary disclosure and settlement negotiation
- Tax elements of restructuring and enforcement
Who we act for
How we work
Judgement applied in a particular order.
The discipline changes; the method does not. These are the decisions we take first on every mandate in this practice.
Read the assessment properly
Most contestable assessments fail on procedure or basis of computation long before the substantive law is reached.
Negotiate from a filed position
Settlements improve markedly once an appeal is properly constituted and the revenue authority understands the case it must meet.
Advise before the exposure
Structuring reviews are cheaper than tribunals. We would rather run the review.
Selected record
Where this practice has been tested.
Nestlé Nigeria Plc v. Federal Inland Revenue Service
Tax Appeal Tribunal
Withholding tax review for an energy group
Advisory
State revenue enforcement challenge
High Court
Common questions
Asked before most instructions.
Can you act after an assessment has become final and conclusive?
Options narrow sharply at that point but are rarely nil. Come to us as soon as the notice of assessment arrives.
Do you handle tax and the underlying commercial dispute together?
Yes — that is the usual shape of the work, particularly in recovery and restructuring mandates.
Consult us
Put the taxation question to a partner.
Every enquiry is read by a partner, cleared for conflicts and acknowledged within one business day. Urgent injunctive or enforcement matters are triaged the same day by telephone.