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Tax

Overview

Trusted tax advisors delivering clarity in planning, compliance, and disputes.

Aluko & Oyebode stands as Nigeria’s premier tax advisory firm, delivering sophisticated solutions to the complex tax challenges facing businesses in Africa’s largest economy. Our tax practice combines decades of specialized expertise with deep commercial insight to serve as the trusted advisor to multinational corporations, financial institutions, energy sector leaders, and high-growth enterprises.

Operating within Nigeria’s intricate tax landscape, characterized by multiple regulatory regimes and evolving compliance frameworks, we provide strategic counsel that goes beyond technical compliance to deliver tangible business value. Our services span corporate tax planning, petroleum profits tax, value-added tax, transfer pricing, withholding tax, and high-stakes tax litigation before Nigerian courts and tribunals.

Through our membership in the Africa Legal Network (ALN), we extend our reach across 14 African jurisdictions, offering clients seamless, continent-wide tax advisory services. This alliance, combined with our relationship with International Law Firms (ILFs), positions us to deliver integrated cross-border solutions that reflect both global best practices and nuanced local knowledge.

Services

Integrated planning across companies income tax, capital gains tax, education tax, stamp duties, sector levies, and incentives. We align tax outcomes with business strategy, from entry and greenfield projects to reorganizations, financing, and exit.

Tax workstreams for buyouts, carve‑outs, joint ventures, project development and finance, capital markets, and debt raises. We optimize structures, step plans, warranties and indemnities, and post‑closing integration.

End‑to‑end management of audits, investigations, objections, settlements, Tax Appeal Tribunal matters, and appellate advocacy. We resolve high‑value assessments and precedent‑setting issues efficiently.

Advice on VAT scope and place‑of‑supply, exemptions and zero‑rating, customs classification and valuation, excise regimes, and sector‑specific levies. We design practical controls for recovery, refunds, and compliance.

Policy design, benchmarking, documentation, audit defense, and advance pricing readiness under Nigeria’s TP Regulations, aligned with OECD/UN guidance to reduce controversy risk.

Compliance frameworks, filings, and interfaces with fiscal authorities. We support submissions on reforms, digital economy rules, indirect transfers, and administration changes under Nigeria’s new tax regime.

Design and implementation of equity and incentive arrangements, payroll and PAYE compliance, mobility and expatriate tax, and workforce structuring.

Personal income tax, residence and treaty reliefs, wealth‑holding structures, and cross‑border succession and asset planning for business owners and executives.

Selected Experience

Acted for Shell in an appeal challenging a decision regarding alleged outstanding personal income tax, addressing core issues in PAYE enforcement and employer obligations at the appellate level. The matter underscores our strength in complex, high‑stakes tax litigation.

Acted for 21 Nigerian commercial banks in coordinated disputes with several state internal revenue services concerning obligations under the Personal Income Tax Act, achieving consistent strategy and efficient resolution across parallel matters.

Defended First Bank of Nigeria in an action initiated by the Lagos State Internal Revenue Service before the High Court of Lagos, advancing arguments on statutory competence and the scope of state tax powers affecting employers.

Won a Federal High Court appeal on behalf of Rand Merchant Bank Nigeria Limited overturning a TAT decision that had upheld WHT on undistributed profits of a close company, clarifying the scope of Section 21 CITA and the limits of administrative discretion.

Acted in landmark matters confirming tax‑exempt status for profits from trading in long‑term bonds, affirming charitable status of an educational institution, and clarifying profit characterization for contracts executed offshore for the benefit of a Nigerian resident.

Client Quotes

Key Contacts

Frame 1618873218
Chukwuka Ikwuazom, SAN
Partner
Frame 1618873219 (3)
Agbada Agbada
Managing Associate

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Awards and Accolades

Thought Leadership

August 2025
Key Points from the Webinar on the Taxation of Non-Residents Under Nigeria’s New Tax Regime
August 2024
Review of Recent Reported Updates on the Taxation of Cryptocurrency in Nigeria
September 2024
An Overview of Deduction of Tax at Source (Withholding) Tax Regulations 2024 and Its Implications on the Existing Tax Regime

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Tax