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Assessment, Objections, Appeals, and Remittances in Nigerian Tax: Complete Guide to Dispute Resolution Under the Tax Reform Acts

Nigeria’s tax landscape has undergone its most fundamental transformation in decades. The enactment of the Nigeria Tax Administration Act 2025 (NTAA 2025) and the Joint Revenue Board (Establishment) Act 2025 (JRBA 2025) has instituted an overhaul of the dispute resolution mechanisms, signalling a profound restructuring of the country’s fiscal rulebook. These reforms have introduced strict timelines, expanded the jurisdiction of the Tax Appeal Tribunal, and created new institutions such as the Office of the Tax Ombud.

The formal pathway for challenging a tax assessment is now clearly defined: an assessment by the tax authority is followed by a taxpayer’s objection, which must be brought within thirty days of the assessment. Where the disagreement persists, an objection is filed at the Tax Appeal Tribunal. Further, section 41(8) and (9) of the NTAA provides for dissatisfied parties to subsequently appeal the TAT’s decision solely on points of law to the Federal High Court, followed by the Court of Appeal, and finally the Supreme Court.

This guide provides a comprehensive examination of the tax dispute resolution framework under Nigeria’s new tax laws, covering assessments, objections, appeals, remittances, and enforcement mechanisms.

The Pain Points: What Taxpayers Are Facing

Let’s be honest. If you’ve ever received a tax assessment in Nigeria, you know the feeling. The anxiety. The confusion. The fear of what might happen next. Here are the specific frustrations many taxpayers are experiencing under the new tax regime.

“I Received a Tax Assessment and I Don’t Know What to Do”

You open your mail or check your email. There it is—a tax assessment notice from the tax authority. The amount is staggering. You don’t agree with it. But you’re not sure what to do next.

Do you pay it? Do you object? What happens if you ignore it? The notice doesn’t explain your rights clearly. And the 30-day deadline is already ticking.

Many taxpayers simply don’t know their rights. They don’t know that they have 30 days to object. They don’t know what a valid objection must contain. They don’t know that the tax authority has 90 days to respond—and if they don’t, the objection is upheld.

This lack of knowledge creates fear. And fear leads to inaction. And inaction leads to final and conclusive assessments—even when the assessment is wrong.

“I Filed My Objection, but Nobody Responded”

You did the right thing. You filed a notice of objection within 30 days. You included all the required details. You provided evidence. And then… nothing.

Weeks pass. Months pass. The tax authority doesn’t respond. You call. You send follow-up emails. You visit their office. Still nothing.

Under the NTAA 2025, the tax authority has 90 days to respond. If they don’t, your objection is upheld. But in practice, many taxpayers don’t know this. They wait patiently. They assume the authority is reviewing their case. Meanwhile, the clock ticks. Interest accrues. Enforcement action looms.

“The Tax Authority Keeps Changing the Rules”

The new tax laws are complex. The NTA 2025 introduces conditional exemptions, domestic sales limits, and a sunset clause. The NTAA 2025 introduces new filing requirements, electronic invoicing, and real-time reporting.

But the rules keep changing. There are conflicting interpretations. Tax officials have different views. Professional bodies are issuing conflicting guidance. And taxpayers are caught in the middle.

How can you comply when the rules are unclear? How can you plan when the rules keep shifting? This uncertainty is a major source of anxiety for businesses.

“I Can’t Afford to Pay 50% Just to Appeal”

Under the Tax Appeal Tribunal Procedure Rules 2021, taxpayers are expected to pay 50% of the disputed amount into a designated account before an appeal is heard. And under the NTAA 2025, taxpayers must pay 20% of the disputed amount before appealing to the Federal High Court.

For large assessments, these amounts can be millions or even billions of naira. Many businesses simply cannot afford to pay this much just to exercise their right to appeal.

This creates a barrier to justice. Taxpayers with valid disputes may be forced to accept unfair assessments because they cannot afford the security deposit. The rich get justice; the poor get compliance.

“The Power of Substitution Scares Me”

Section 60 of the NTAA 2025 authorises tax authorities to appoint any person as the agent of a taxable person where tax has become due and payable and remains unpaid. In plain English: the tax authority can go directly to your bank, your tenant, or your employer and seize funds without a court order.

This power is frightening. It can be exercised without prior judicial authorisation. Your bank account could be frozen. Your rent could be redirected. Your salary could be garnished. All without a court order.

Yes, there are safeguards. Yes, you can challenge it. But by the time you challenge it, the damage may already be done. Your cash flow is disrupted. Your business is destabilised. Your reputation is damaged.

“I Keep Hearing About the Tax Ombud, but I Don’t Know How to Use It”

The Joint Revenue Board (Establishment) Act 2025 created the Office of the Tax Ombud (OTO) as an independent institution to protect taxpayers’ rights and fairly resolve disputes. The Federal Government has unveiled digital platforms for the OTO to strengthen transparency, accountability, and fairness.

But many taxpayers don’t know about the OTO. They don’t know how to access it. They don’t know what it can do for them. They don’t know whether it’s better than the Tax Appeal Tribunal or the courts.

This lack of awareness means that a valuable resource is underutilised. Taxpayers who could benefit from the OTO’s services don’t even know it exists.

“The Process Takes Too Long”

Tax disputes in Nigeria can drag on for years. Assessments. Objections. Appeals. Further appeals. Each stage has its own timeline and its own hurdles. By the time the dispute is resolved, the business may have been destabilised. The cash flow may have been disrupted. The opportunity may have been lost.

The new laws are trying to fix this. The 90-day response rule is a step in the right direction. But in practice, delays remain a major source of frustration.

“I Feel Like the System Is Stacked Against Me”

When you’re a small business, you feel like the tax authority has all the power. They have the resources. They have the legal expertise. They have the power to seize your assets. You feel like David facing Goliath.

You don’t have a team of tax lawyers. You don’t have a dedicated compliance department. You don’t have the resources to fight a protracted dispute. So you pay. Even when you shouldn’t have to. Even when the assessment is wrong.

Part 1: Tax Assessments — The Foundation of Dispute Resolution

What Is a Tax Assessment?

A tax assessment is the formal determination by a tax authority of a taxpayer’s liability for a particular tax period. Under the NTAA 2025, a tax liability only crystallises after formal assessment has been issued, properly served, and either accepted by the taxpayer or confirmed through the objection and appeal framework.

The Act devotes extensive provisions to assessments, service of notices, timelines for payment, and the rights of taxpayers to object and appeal. This architecture ensures that tax does not become “due and payable” by administrative whim but through a structured statutory process.

Types of Assessments

1. Self-Assessment
Taxpayers are required to compute and file their own tax liabilities through self-assessment returns. This is the most common form of assessment, where the taxpayer determines their liability and files accordingly.

2. Best of Judgment Assessment
Where a taxpayer fails to file returns or provides inadequate information, the tax authority may issue a Best of Judgment (BOJ) assessment. This is an estimate of the taxpayer’s liability based on the best information available to the authority.

3. Additional Assessment
Where the tax authority discovers that an assessment is insufficient or that income has escaped assessment, it may issue an additional assessment. Nigerian tax laws provide for the issuance of an additional assessment notice on the taxpayer, who has a period of 30 days from the date of the notice to object.

4. Amended Assessment
Where the taxpayer and the tax authority agree as to the amount of tax to be assessed, the disputed assessment shall be amended and a revised notice of the tax payable shall be served on the taxpayer.

Service of Assessment Notices

Proper service of assessment notices is a critical procedural requirement. The Tax Appeal Tribunal has held that failure to properly serve a notice of assessment renders the assessment null and void. In the case of Popham Walter Odusote Ltd v. Bayelsa State Board of Internal Revenue, the Tribunal nullified a N1.13 billion tax assessment because the tax authority failed to prove that it properly notified the taxpayer before conducting the tax audit or issuing the assessment.

When Does an Assessment Become Final and Conclusive?

Under Section 43 of the NTAA, a tax liability becomes final and conclusive under any of the following conditions:

When no valid objection or appeal is filed within the legally specified time

When a taxpayer agrees to an assessed income or profit under Section 41(5)

When the amount is determined following an objection or revised under Section 41(5)

When an assessment has been agreed to, revised, or settled on appeal

Failure to appeal against an assessment within the statutory time frame makes it conclusive and final, even if the assessment is inaccurate. Once a tax assessment has become final, full payment of the tax is required to be made within 30 days of the service of a Notice of Assessment.

Part 2: Objections — The First Line of Defence

The 30-Day Objection Window

Under Section 41(2)(a) of the NTAA 2025, where a taxpayer disputes an assessment by the tax authority, the taxpayer must lodge a written notice of objection within 30 days of the assessment. Once the tax authority issues an assessment, the taxpayer has 30 days to pay or object.

This timeframe may be extended by the relevant tax authority for any satisfactory and good cause shown. However, taxpayers should not rely on such extensions and must act promptly to protect their rights.

Requirements for a Valid Notice of Objection

Section 41(2) of the NTAA 2025 requires that a notice of objection shall only be valid if it:

Is delivered to the relevant tax authority within 30 days from the date of service of the disputed notice of assessment
Contains the grounds of objection to the assessment, including:

Specific issues disputed or errors observed with their monetary values

Amendment required to be made so as to resolve the dispute or correct the error

Justification for the amendments

Amount of assessable and total profits, income or value of transactions admitted by the taxable person

Amount of tax admitted by the taxable person or that no amount of tax is admitted as payable

Objections must be precise and evidence-driven. A taxpayer who disputes an assessment may lodge a notice of objection with the relevant tax authority within the period of 30 days. The objection must clearly identify the items being disputed and explain why an adjustment is being requested.

Tax Authority’s Response to Objection

Upon receipt of the notice of objection, the relevant tax authority may:

Require the taxable person to furnish such particulars as it may deem necessary and to produce all books or other documents

Summon any person to give evidence in respect of the assessment to appear for examination before an authorised officer

Make a declaration on oath in respect of the assessment

The 90-Day Response Rule

The relevant tax authority must respond to the objection notice within 90 days, otherwise the objection of the taxpayer shall be upheld. This is a significant departure from the previous regime where there was no statutory timeline for the tax authority’s response.

As noted in Nigerian jurisprudence, the computation of the 90-day limit includes every calendar day, including weekends and public holidays. This means that tax officials will face immense pressure to promptly review and revise assessments.

Consequences of Tax Authority’s Failure to Respond

The statute’s wording on the 90-day response rule is unequivocal. Where an under-resourced tax office fails to respond in time on a complex corporate audit, the assessment is truly overturned. Corporate tax departments are well advised to diarise and closely follow that 90-day window.

Where the relevant tax authority considers the notice of objection invalid or where the taxpayer and the relevant tax authority do not agree as to the amount of tax to be assessed, the taxpayer may exercise the right of appeal.

Part 3: Appeals — Escalating the Dispute

Appeal to the Tax Appeal Tribunal

Once the tax authority issues a decision on the objection and the taxpayer remains dissatisfied, the next step is to seek recourse at the Tax Appeal Tribunal (TAT).

Section 29 of the JRBA unequivocally grants TAT jurisdiction over disputes emanating from the Nigeria Tax Act, the Nigeria Tax Administration Act, tax laws of the National Assembly and importantly, laws from the Houses of Assembly of States. The Act now empowers the TAT to determine disputes arising not only from federal tax laws but also from tax laws enacted by State Houses of Assembly.

The TAT is an administrative tribunal and a condition precedent that must be fulfilled before the jurisdiction of the Federal High Court is triggered. It is purely an administrative tribunal, one which serves as the last fact-finding body in tax disputes.

Timeframe for Filing an Appeal

Taxpayers or tax authorities may within 30 days appeal against assessments, demand notices, actions, decisions or non-compliance. An appeal to the TAT against the decision of the tax authority is required to be made within 30 days of receiving the decision.

The Tribunal may entertain an appeal filed after the expiry of the 30-day window where the Tribunal is satisfied that there was sufficient cause for the delay. A tax authority may also appeal to the Tribunal in the Zone where a taxpayer is resident, where the tax authority is aggrieved by the non-compliance of the taxpayer.

The Tax Appeal Tribunal Procedure Rules 2021

All proceedings before the Tribunal are guided by the Tax Appeal Tribunal (Procedure) Rules 2021. Key features of the Rules include:

Electronic filing and service of documents

Place of filing appeals determined by the taxpayer’s domicile

Mandatory payment of 50% of tax assessed as security for the appeal

Documents only procedure for hearing appeals

Six-month timeframe from the date of commencement of trial for the TAT to conclude and provide a decision

Before an appeal is heard, taxpayers are expected to pay 50% of the disputed amount into a designated account of the TAT. The taxpayer must file a deposition along with the appeal to that effect.

TAT’s Commitment to Alternative Dispute Resolution

The Tax Appeal Tribunal (Procedure) Rules, 2021, have strengthened the Tribunal’s commitment to Alternative Dispute Resolution (ADR), explicitly empowering it to encourage, promote, and facilitate amicable settlements. The Tribunal’s pre-hearing conference mechanism encourages settlement, offers flexibility in proceedings. Several appeals filed before the Tribunal have been resolved amicably, without proceeding to full trial.

Appeals to the Federal High Court

Any party aggrieved by a decision of the Tribunal has the right to appeal to the Federal High Court within 30 days after the date on which the decision was given. An appeal to the Federal High Court shall be on points of law only.

Where a taxpayer is dissatisfied with the judgement of the Tax Appeal Tribunal, it may appeal to the High Court, provided that it shall pay 20% of the disputed amount into an account designated by the High Court as security before the hearing of the appeal, and include the evidence of payment while filing the notice of the appeal.

Further Appeals

A party dissatisfied with the decision of the High Court may appeal to the Court of Appeal, while an appeal against the judgement of the Court of Appeal shall be to the Supreme Court. The Supreme Court’s decision is final.

Part 4: Alternative Dispute Resolution Mechanisms

Amicable Settlement Under Section 141 NTAA 2025

Section 141 of the NTAA 2025 allows for settlement of tax disputes amicably, indicating the applicability of ADR in tax disputes. Section 141(1) provides that without prejudice to any provision of this Act or any other law, the relevant tax authority and the taxable person may initiate to resolve any tax matters amicably at any stage of the dispute.

The new tax dispensation allows for the amicable settlement of disputes between a taxpayer and a tax authority, and the settlement may be initiated by either party at any stage of a dispute. The dispute may also be settled in whole or in part.

However, the law permits amicable settlement only where:

Such settlement will be in the interest of public revenue or public policy

Due consideration is given to the cost of litigation in comparison to the possible benefits

The settlement will facilitate disclosure of hidden tax planning and evasion schemes that may lead to significant tax recovery

Some agreement has been reached between a party or group of participants in a legal arrangement and the relevant tax authority

Limitations on Amicable Settlement

Amicable settlement is not allowed where:

Intentional tax evasion or a fraud inimical to government revenue is discovered on the part of the taxpayer

It is in the public interest to have judicial clarification of the tax issue involved for the purpose of promoting taxpayer compliance

Binding Effect of Settlement Agreements

A settlement agreement duly endorsed by the parties to a tax dispute is a final decision which is binding on the parties, and the tax authority has the power to enforce collection of the settlement amount as a tax debt owed by the taxpayer.

Where an appeal is before the Tribunal for the first time, the Chairman of the Tribunal may grant parties to the tax dispute a maximum of 30 days within which to explore the possibilities for amicable settlement, after which the case shall proceed to trial.

The Office of the Tax Ombud

The Joint Revenue Board (Establishment) Act 2025 created two distinct but interrelated institutions: the Tax Appeal Tribunal (TAT) and the Office of the Tax Ombud (OTO). The OTO serves as an independent institution to protect taxpayers’ rights and fairly resolve disputes.

The OTO is not a replacement for the Tax Appeal Tribunal or the courts. If taxpayers have concerns about tax assessments or administrative actions, they can bring their cases to the OTO. The OTO reviews the issues, engages relevant authorities, and seeks amicable solutions. Where parties remain dissatisfied, they retain the right to proceed to the Tax Appeal Tribunal.

The Federal Government has unveiled digital platforms for the Office of the Tax Ombud to strengthen transparency, accountability and fairness in Nigeria’s tax administration system. Citizens can initiate cases, request information, or speak directly with trained support personnel without incurring financial costs.

Part 5: Remittances — Payment of Tax

General Payment Obligations

Where there is no objection to or appeal against an assessment or where a tax assessment has become final, full payment of the tax is required to be made within 30 days of the service of a Notice of Assessment on a taxpayer.

Electronic Filing and Payment Platforms

The Nigeria Revenue Service (NRS) requires taxpayers to file returns on the e-filing platform. Taxpayers must complete the online filing process in order to generate a Remita Retrieval Reference (RRR) number for the payment of the relevant taxes either through the Remita portal or at the bank.

The key steps for tax remittance include:

Visit the Remita portal on any web browser

Select the specific tax you want to pay under the “Name of service/purpose” section

Fill out the required information and click Submit

Choose your preferred payment method

VAT Remittance

VAT payments are made through the TaxPro Max portal or designated banks. After filing and remittance, taxpayers should download and keep the acknowledgment receipt as proof of compliance.

Taxpayers must complete the online filing process in order to generate a Remita Retrieval Reference number for the payment of VAT.

Withholding Tax Remittance

For Withholding Tax remittance, taxpayers must:

Log into TaxPro Max

Navigate to “Withholding Tax” from the dashboard

Upload the WHT schedule

Make payment and generate an e-receipt as proof of remittance

Remittance must be supported by a detailed schedule containing the contractor’s or supplier’s name and Tax Identification Number (TIN).

PAYE Remittance

Employers are required to deduct PAYE from employees’ salaries and remit it monthly to the relevant tax authority before the 10th day of the following month. Employers can make PAYE remittance through the following platforms:

Online, through Remita

Direct payment at any of the four designated banks

TaxPro Max Portal

The TaxPro Max portal is the primary platform for federal tax filings and payments. Users generating a Payment Reference Number (PRN) on the platform have the option of paying through various payment gateways or at bank branches.

Automated Tax Remittance System (ATRS)

The Automated Tax Remittance System (ATRS) is a live REST API that enables automated tax remittance. To register for ATRS:

Create an account on the eCitizen portal
Submit your ATRS application through the eCitizen portal
You will need your business TIN

Part 6: Enforcement — The Power of Substitution

What Is the Power of Substitution?

At the core of the controversy surrounding Nigeria’s new tax regime is Section 60 of the NTAA 2025, which expressly authorises the relevant tax authority, without an order of court and by notice in writing, to appoint any person as the agent of a taxable person where tax has become due and payable and remains unpaid, or where that person is in possession of, or is likely to be in possession of, funds belonging to the taxpayer.

This provision forms the legal foundation for directives to banks or other third parties to remit taxpayers’ funds. The wording establishes substitution as an administrative enforcement power rather than a judicial process, intended to secure payment of tax debts that are already legally due.

How Substitution Works

Section 60 of the NTAA 2025 authorises tax authorities to invoke the power of substitution where a taxpayer fails to pay an assessed and final tax liability when due. Tax authorities may issue substitution notices to:

Banks and other financial institutions

Employers

Tenants

Any person holding or owing money to a tax defaulter

These notices direct them to remit such funds to the service in settlement of the debt.

The Statutory Safeguards

Substitution sits at the extreme end of a statutory chain that begins with inquiry and assessment, passes through objection and appeal, and only culminates in enforcement after legal finality. This architecture makes it impossible, in law, for substitution to operate as a first resort or discretionary revenue shortcut.

Subsection (5) provides that any notice issued under the section shall, for objections and appeals, be treated as if it were an assessment or demand notice. This ensures that taxpayers may challenge substitution through statutory objection processes, the Tax Appeal Tribunal, the Federal High Court, and appellate courts.

Judicial Oversight

The absence of prior judicial authorisation does not mean that substitution operates outside the courts’ control. Judicial oversight is structured as post-enforcement review rather than pre-enforcement permission. Appointed agents, including banks, may also contest notices where no funds are held or directives were improperly issued.

Nigeria’s Approach in Global Context

Nigeria’s approach aligns with jurisdictions such as the United Kingdom, South Africa, Canada, and Australia, where third-party or garnishee-type notices are routine administrative tools to recover confirmed tax debts.

Part 7: Practical Tips and Best Practices

For Taxpayers

1. Act Within 30 Days
The 30-day objection window is strictly enforced. Once a tax authority issues an assessment, you have 30 days to pay or object. Failure to act within this timeframe makes the assessment final and conclusive.

2. File a Proper Notice of Objection
Your notice of objection must be precise and evidence-driven. It must clearly identify the items being disputed, explain why an adjustment is being requested, and specify the monetary values involved.

3. Diarise the 90-Day Response Window
The tax authority has 90 days to respond to your objection. If they fail to respond within this timeframe, your objection is upheld. Corporate tax departments should closely follow this 90-day window.

4. Consider Alternative Dispute Resolution
Amicable settlement under Section 141 of the NTAA can be a faster, less costly alternative to litigation. Settlement and reconciliation can be binding if properly executed.

5. Keep Meticulous Records
Documentary evidence is critical in tax disputes. Financial records, tax returns, and correspondence between the taxpayer and tax authorities are essential.

For Boards and Directors

1. Exercise Board-Level Oversight
Tax is a material financial and regulatory risk requiring board-level oversight. Directors must maintain awareness of applicable tax laws and exercise oversight of risk management systems.

2. Understand Material Tax Exposures
Directors must understand material tax exposures and their financial implications, ensure thorough compliance, maintain reporting systems, and seek expert advice on complex issues.

3. Monitor Deadlines
The strict timelines under the NTAA 2025 — 30 days for objections, 90 days for tax authority response — require active monitoring by management and boards.

For Tax Professionals

1. Ensure Precision in Objections
Objections must be precise and evidence-driven. Vague or general objections may be deemed invalid.

2. Understand the New Timelines
The NTAA 2025 introduces strict timelines for objections and appeals. Professionals must familiarise themselves with these deadlines.

3. Leverage ADR Mechanisms
The new tax dispensation allows for amicable settlement of disputes. Professionals should consider ADR as a viable option for resolving disputes.

4. Stay Current with Developments
The tax dispute resolution landscape is evolving rapidly. Professionals must stay current with new legislation, regulations, and judicial decisions.

How Qeeva Advisory Steps In

At Qeeva Advisory, we understand that navigating Nigeria’s new tax dispute resolution framework can be overwhelming. From strict 30-day objection deadlines to complex appeal procedures and the looming threat of substitution, taxpayers face significant challenges. We’re here to help you every step of the way.

Our Advisory Services provide expert guidance across the legal, business, and financial aspects of your tax disputes. With professionals who have over 12 years of experience in investments, taxation, corporate advice, and financial management, we ensure that our clients receive practical, efficient, and quick-fix solutions to their tax problems. We specialise in guiding businesses of all sizes—whether small, medium, or large—through the complexities of the NTAA 2025.

Our Regulatory Compliance services help you maintain good standing with tax authorities and avoid costly penalties. We ensure your business meets all filing requirements—including VAT, WHT, PAYE, and annual returns—while keeping you informed of your rights under the new tax laws. Compliance is not just a legal requirement; as we emphasise, “it is a business strategy that fosters stability, trust, and growth”.

When disputes arise, our Tax Disputes Support provides expert representation at every stage—from filing a valid notice of objection to appealing to the Tax Appeal Tribunal and beyond. We help you navigate the strict timelines, prepare the required documentation, and meet the security deposit requirements for appeals.

For businesses concerned about the power of substitution under Section 60 of the NTAA, our Risk Management Services help you identify, quantify, and proactively manage tax-related risks. Our comprehensive offerings encompass regulatory compliance, fraud prevention, and risk governance, ensuring you are prepared for enforcement actions.

And because tax disputes are fundamentally about protecting your business, our Business Strategy Consulting Services help you develop strategies that position your business for long-term sustainability while managing tax risks effectively.

Our Service Methodology

We don’t do generic. We do thorough, transparent, and actionable.

Step 1: Tax Assessment Review & Audit
We review your tax assessment notices, financial records, and correspondence with tax authorities. We identify errors, inconsistencies, and areas where the assessment may be incorrect or excessive.

This step draws on our Advisory Services expertise to identify gaps and opportunities, and our Regulatory Compliance knowledge to ensure your records meet statutory requirements.

Step 2: Objection & Appeal Strategy Development
We develop a comprehensive strategy for challenging the assessment, including drafting a precise and evidence-driven notice of objection within the 30-day window. We ensure your objection meets all statutory requirements under Section 41(2) of the NTAA 2025.

Our Tax Disputes Support team comes into play here, helping you identify the grounds of objection and prepare the necessary documentation.

Step 3: Representation & Advocacy
If the objection is not resolved, we represent you before the Tax Appeal Tribunal, the Federal High Court, and appellate courts. We manage all procedural requirements, including security deposits, filings, and hearings.

Our Advisory Services team ensures you are fully prepared for each stage of the dispute resolution process.

Step 4: Alternative Dispute Resolution
Where appropriate, we pursue amicable settlement under Section 141 of the NTAA 2025. We negotiate with tax authorities to resolve disputes efficiently and cost-effectively, avoiding protracted litigation.

For this, we lean on our Risk Management Services to evaluate settlement options and our Advisory Services to negotiate favourable terms.

Step 5: Enforcement Defence & Compliance Restoration
If substitution notices are issued or enforcement action is threatened, we help you respond promptly and protect your assets. We ensure you understand your rights and can challenge enforcement actions through the statutory objection and appeal processes.

We keep your financial systems in order with our compliance support and ensure you remain on the right side of the law with our Regulatory Compliance services.

Key Takeaways

The NTAA 2025 and JRBA 2025 have fundamentally reinvented Nigeria’s tax dispute resolution system. The formal pathway for a merits-based challenge is now clearly defined: assessment, objection within 30 days, appeal to the Tax Appeal Tribunal, and further appeals to the Federal High Court, Court of Appeal, and Supreme Court.

The key timelines are:

30 days to file a notice of objection from the date of service of assessment

90 days for the tax authority to respond to an objection

30 days to appeal to the Tax Appeal Tribunal

30 days to appeal to the Federal High Court from a TAT decision

20% deposit of disputed amount required for appeal to the High Court

50% deposit of disputed amount required for appeal to the TAT

The new institutions include:

The Tax Appeal Tribunal (TAT) with expanded jurisdiction over federal and state tax disputes

The Office of the Tax Ombud (OTO) for independent dispute resolution

Amicable settlement provisions under Section 141 of the NTAA

The enforcement mechanisms include:

The power of substitution under Section 60 of the NTAA

Post-enforcement judicial review

The bottom line: The era of indefinite tax disputes in Nigeria has ended. The NTAA 2025 introduces a performance-based, timeline-driven dispute resolution framework that balances taxpayer rights with efficient revenue collection. Taxpayers who understand and leverage these mechanisms will be best positioned to protect their rights and resolve disputes efficiently.

Let’s Talk About Your Tax Dispute Resolution Needs

Navigating Nigeria’s new tax dispute resolution framework can be complex. At Qeeva Advisory, we understand the challenges taxpayers face under the NTAA 2025—from strict timelines to complex appeal procedures and enforcement mechanisms.

Whether you need help with:

Understanding your tax assessment and dispute resolution options

Filing a valid notice of objection within the 30-day window

Appealing to the Tax Appeal Tribunal and navigating the TAT Procedure Rules

Negotiating amicable settlements under Section 141 of the NTAA

Engaging with the Office of the Tax Ombud for independent dispute resolution

Managing tax remittances and compliance obligations

Defending against substitution notices and enforcement actions

We’re here to support you every step of the way.

📞 Call us: (+234) 802 320 0801, (+234) 807 576 5799

📧 Email: info@qeeva.com

📍 Visit us: 5, Ishola Bello Close, Off Iyalla Street, Alausa, Ikeja, Lagos, Nigeria

Contact us today to schedule a consultation. Let us help you navigate Nigeria’s new tax dispute resolution landscape with confidence.

Related Services

We offer specialised services to help taxpayers navigate Nigeria’s new tax dispute resolution framework:

Advisory Services – Expert guidance across legal, business, and financial aspects of tax disputes. Our professionals specialise in taxation, corporate advice, and financial management with over 12 years of experience.

Tax Disputes Support – When disputes arise with tax authorities, our team provides expert representation. We help taxpayers navigate objections, appeals, and enforcement actions.

Regulatory Compliance – Ensure your business meets all filing requirements and maintains good standing with tax authorities. Compliance is a business strategy that fosters stability, trust, and growth.

Risk Management Services – Identify, quantify, and proactively manage tax-related risks across various domains, including regulatory compliance and fraud prevention.

Business Strategy Consulting Services – Develop strategies that position your business for long-term sustainability while managing tax risks effectively.