Tax Audit Defence Service
Prepare with Confidence. Defend with Expertise. Protect Your Business.
A tax audit is one of the most stressful events any Nigerian business can face. Whether it is a desk review, a comprehensive audit, or a full-scale investigation by the Federal Inland Revenue Service (FIRS), State Internal Revenue Service, or the Nigeria Revenue Service (NRS), the process can disrupt operations, consume management time, and expose your business to significant penalties and interest if not handled correctly. Under the Nigeria Tax Administration Act (NTAA) 2025, tax authorities now have expanded powers, and the penalties for non-compliance—including ₦100,000 for the first month of late filing and 10% of unremitted tax plus interest at the CBN rate—are substantial. At Qeeva Advisory, we provide tax audit defence services that help you prepare with confidence, defend with expertise, and protect your business.
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Why Nigerian Businesses Need Tax Audit Defence Services
Tax audits have become more frequent, more data-driven, and more consequential. Here are the most critical gaps we help you address.
Expanded Audit Powers Under the NTAA 2025 – The Nigeria Tax Administration Act 2025 significantly expanded the powers of tax authorities. The Act mandates full adoption of electronic fiscalisation, enabling real-time visibility into transactions. The Nigeria Revenue Service now cross-references TIN databases with corporate affairs records and bank data, meaning any mismatch can trigger automatic queries and penalties. The era of “nobody is checking me” is over.
Data-Driven Enforcement – The NRS has deployed digital tools including TaxPro-Max, e-invoicing (Merchant Buyer Solution), and automated audit systems. These systems provide greater visibility across industries. In a digital tax environment, poor data quality has shifted from a minor inconvenience to a significant business risk.
Severe Penalties for Non-Compliance – Penalties under the NTAA 2025 are severe. Late filing of VAT returns attracts ₦100,000 for the first month of default and ₦50,000 for every month after; failure to register for tax attracts ₦50,000; failure to maintain proper records can cost a company ₦50,000. Penalties for non-compliance with e-invoicing are even higher. Interest on outstanding tax accrues at the CBN Monetary Policy Rate.
Common Audit Triggers – Audits are frequently triggered by discrepancies between filed returns and bank data, mismatch between VAT output and income tax returns, late or missed filings, refusal to file returns, petitions from employees regarding PAYE, unexplained large transactions, and transfer pricing issues. Understanding these triggers helps you avoid unnecessary audits.
Transfer Pricing Exposure – Related-party transactions and transfer pricing are increasingly scrutinised. The NTA 2025 and NTAA 2025 strengthen transfer pricing documentation requirements. Businesses without proper transfer pricing documentation face significant exposure.
Input VAT Recovery Scrutiny – With the expanded input VAT recovery regime under the NTA 2025, tax authorities are scrutinising input VAT claims more closely. Documentation of the link between input VAT and taxable supplies is essential.
VAT and Capital Allowance Linkage – Under section 21(p) of the NTA, VAT must be charged and paid on all taxable supplies before the underlying expense can qualify as allowable for income tax purposes. For capital assets, failure to charge VAT or pay import duty renders the asset ineligible for capital allowances. This creates a critical audit nexus.
Payroll and PAYE Audits – Employers face audits on PAYE compliance, including correctness of deductions, timeliness of remittances, and compliance with the Personal Income Tax Act. LIRS and FIRS audits frequently focus on PAYE.
Director and Officer Liability – Directors can be personally liable for tax non-compliance, including penalties and interest. Director disqualification is also possible.
Reputational and Operational Disruption – Tax audits consume management time, disrupt operations, and create reputational risk. How you handle an audit determines whether it is a manageable exercise or a business-threatening event.
Transfer from FIRS to NRS – The Nigeria Revenue Service has replaced the FIRS in key administrative roles, and the transition has created some uncertainty. Businesses need advisers who understand the new administrative structure.
The Solution: Strategic Tax Audit Defence
We provide tax audit defence services that help you prepare with confidence, defend with expertise, and protect your business. Our approach combines pre-audit preparation, audit representation, technical defence, and post-audit remediation.
At Qeeva Advisory, we understand that tax audits are won or lost before they begin. Proper documentation, accurate filings, and robust records are your strongest defence. When an audit does occur, experienced representation makes a decisive difference. Our team brings deep expertise in Nigerian tax law, audit procedures, and dispute resolution.
We help you prepare for audits, represent you during audits, challenge assessments, and resolve disputes. Our goal is to achieve the best possible outcome—whether that means no adjustment, reduced assessment, or a negotiated settlement.
Whether you need pre-audit preparation, audit representation, technical defence, or complete tax audit defence, we provide the expertise and commitment to help you succeed.
Our Comprehensive Tax Audit Defence Services
We offer end-to-end tax audit defence services tailored to the Nigerian tax environment.
Pre-Audit Preparation
We help you prepare for audits before they occur.
Tax Compliance Health Check – We conduct comprehensive reviews of your tax compliance across CIT, VAT, WHT, PAYE, and other taxes, identifying gaps and risks.
Tax Risk Assessment – We assess your exposure to tax audit adjustments, penalties, and interest.
Record-Keeping Review – We review your tax records for completeness, accuracy, and audit readiness. Under the NTAA 2025, failure to maintain proper records can cost a company ₦50,000.
Documentation Systems – We help you establish documentation systems that support audit defence, including contracts, invoices, payment evidence, and correspondence.
Transfer Pricing Documentation – We prepare and review transfer pricing documentation, ensuring compliance with Nigerian transfer pricing regulations.
VAT Documentation – We ensure input VAT claims are supported by proper documentation linking input VAT to taxable supplies.
TIN Verification – We verify TIN compliance for your business and your vendors. From 2026, a company’s CAC registration number becomes its primary Tax ID.
Audit Readiness Training – We train your finance team on audit procedures, documentation requirements, and how to respond to audit queries.
Mock Audits – We conduct mock audits that simulate real audit conditions, identifying weaknesses and preparing your team.
Audit Trigger Analysis – We analyse common audit triggers and help you address potential exposures.
Audit Representation
We represent you during tax audits.
Audit Notification Response – We help you respond to audit notifications appropriately, ensuring you understand the scope and requirements.
Audit Planning and Strategy – We develop audit defence strategies tailored to the specific audit, including scope, issues, and anticipated questions.
Liaison with Tax Authorities – We act as your representative in communications with FIRS, NRS, LIRS, and other tax authorities.
Audit Meeting Attendance – We attend audit meetings with you, ensuring technical accuracy and appropriate representation.
Document Production Management – We manage document production, ensuring all requested documents are provided accurately and completely.
Auditor Query Management – We manage auditor queries, ensuring timely and accurate responses.
Technical Defence – We provide technical defence on complex tax issues, including transfer pricing, input VAT recovery, and capital allowance claims.
Position Papers – We prepare position papers that explain your tax position and support your filings with relevant law and precedent.
Negotiation – We negotiate with tax authorities to reach fair and sustainable outcomes.
VAT Audit Defence
We defend you against VAT audits.
Input VAT Recovery Defence – We defend input VAT claims, demonstrating the link between input VAT and taxable supplies under the NTA 2025.
Output VAT Defence – We defend output VAT calculations, ensuring accuracy and completeness.
E-Invoicing Compliance Defence – We defend against e-invoicing non-compliance claims, addressing Merchant Buyer Solution (MBS) requirements.
Self-Charge Defence – We defend self-charge obligations where vendors have not charged VAT.
VAT Refund Claims – We support VAT refund claims, ensuring they are submitted within 12 months and processed within 30 days.
VAT Assessment Challenges – We challenge VAT assessments that are inaccurate or excessive.
Transfer Pricing Audit Defence
We defend you against transfer pricing audits.
Transfer Pricing Documentation Review – We review your transfer pricing documentation for compliance with Nigerian regulations.
Benchmarking Studies – We conduct benchmarking studies that support your transfer pricing positions.
Related-Party Transaction Defence – We defend related-party transactions, demonstrating arm’s length pricing.
Advance Pricing Agreements (APAs) – We advise on APAs as a mechanism for securing certainty.
Mutual Agreement Procedures (MAPs) – We support MAPs where double taxation arises.
Transfer Pricing Assessment Challenges – We challenge transfer pricing assessments that are unsupported or excessive.
PAYE and Payroll Audit Defence
We defend you against PAYE and payroll audits.
PAYE Compliance Review – We review PAYE compliance, including correctness of deductions and timeliness of remittances.
PAYE Remittance Reconciliation – We reconcile PAYE deductions with remittances, identifying and addressing discrepancies.
Employee Benefit Audit Defence – We defend employee benefit arrangements, including allowances, benefits-in-kind, and share schemes.
LIRS and FIRS Representation – We represent you before LIRS and FIRS on PAYE matters.
PAYE Assessment Challenges – We challenge PAYE assessments that are inaccurate or excessive.
CIT and Income Tax Audit Defence
We defend you against CIT and income tax audits.
CIT Return Review – We review CIT returns for accuracy and compliance.
Capital Allowance Defence – We defend capital allowance claims, ensuring the VAT-capital allowance linkage is satisfied.
Deferred Tax Defence – We defend deferred tax positions, including deferred tax asset recoverability.
Business Restructuring Defence – We defend business restructuring transactions from tax challenge.
Loss Relief Defence – We defend loss relief claims, ensuring compliance with minimum tax and loss relief rules.
CIT Assessment Challenges – We challenge CIT assessments that are inaccurate or excessive.
WHT Audit Defence
We defend you against WHT audits.
WHT Compliance Review – We review WHT compliance, including deductions, remittances, and credit notes.
WHT Credit Reconciliation – We reconcile WHT credits with FIRS records, resolving discrepancies.
WHT Assessment Challenges – We challenge WHT assessments that are inaccurate or excessive.
WHT Refund Claims – We support WHT refund claims.
Audit Dispute Resolution
We resolve tax disputes with tax authorities.
Objection and Appeal Preparation – We prepare objections and appeals to tax assessments.
Tax Appeal Tribunal Representation – We represent you before the Tax Appeal Tribunal.
Alternative Dispute Resolution – We support ADR of tax disputes, including mediation and negotiation.
Litigation Support – We support tax litigation, working with external counsel.
Settlement Negotiation – We negotiate settlements that resolve disputes efficiently.
Penalty and Interest Negotiation – We negotiate reductions or waivers of penalties and interest.
Voluntary Disclosure and Remediation
We help you address past non-compliance.
Voluntary Disclosure Advisory – We advise on voluntary disclosure of past non-compliance, including the benefits and risks.
Amended Returns Preparation – We prepare amended returns that correct past errors.
Remediation Planning – We develop remediation plans that address past non-compliance and prevent recurrence.
Penalty Mitigation – We support penalty mitigation through voluntary disclosure and remediation.
Post-Audit Remediation
We help you address audit findings and prevent recurrence.
Audit Finding Analysis – We analyse audit findings, identifying root causes and systemic issues.
Remediation Implementation – We support implementation of remediation actions, including process and system changes.
Control Strengthening – We strengthen tax controls to prevent recurrence.
Training and Capacity Building – We train your team on tax compliance and audit readiness.
Ongoing Monitoring – We establish ongoing monitoring that tracks tax compliance and identifies issues early.
Common Tax Audit Triggers
We help you avoid and defend against common audit triggers.
| Trigger | Description | Mitigation |
|---|---|---|
| Bank Data Mismatch | Filed returns inconsistent with bank transaction data | Reconcile returns with bank data |
| VAT/Income Tax Mismatch | VAT output inconsistent with income tax returns | Ensure consistency across returns |
| Late or Missed Filings | Late or missed returns attract scrutiny | File on time; address backlog |
| PAYE Petitions | Employee petitions regarding PAYE deductions | Ensure accurate PAYE deductions |
| Unexplained Transactions | Large or unusual transactions without documentation | Maintain documentation |
| Transfer Pricing Issues | Related-party transactions without documentation | Prepare transfer pricing documentation |
| Input VAT Claims | Input VAT claims without supporting documentation | Document link to taxable supplies |
| Capital Allowance Claims | Capital allowance claims without VAT compliance | Ensure VAT charged and paid |
| E-Invoicing Non-Compliance | Failure to process supplies through MBS | Implement e-invoicing |
Industries We Serve
We provide tax audit defence services across multiple sectors in Nigeria.
Banking and Financial Services – We defend banks, insurance companies, and financial institutions on CIT, VAT, WHT, and transfer pricing audits.
Manufacturing – We defend manufacturers on capital allowance, input VAT, and inventory audits.
Oil and Gas – We defend energy companies on petroleum profits tax, VAT, and transfer pricing audits.
Technology and Digital – We defend tech companies on digital services VAT, SEP rules, and transfer pricing.
Retail and Consumer Goods – We defend retailers on VAT, inventory, and CIT audits.
Healthcare – We defend healthcare organisations on VAT exemptions, PAYE, and CIT audits.
Professional Services – We defend professional service firms on input VAT recovery, PAYE, and CIT audits.
Real Estate and Construction – We defend developers on VAT exemptions, WHT, and CIT audits.
Logistics and Transportation – We defend logistics companies on VAT, WHT, and CIT audits.
Hospitality – We defend hotels and restaurants on VAT, PAYE, and CIT audits.
E-commerce and Marketplaces – We defend marketplaces on VAT on commissions, service fees, and digital supplies.
Non-Profit and NGOs – We defend mission-driven organisations on tax exemptions and compliance.
SMEs – We provide accessible tax audit defence for SMEs.
Our Engagement Process
We follow a structured, collaborative process to deliver high-impact tax audit defence.
Phase 1: Discovery and Assessment – We understand your tax position, compliance history, and audit risk. We assess exposure and identify priorities.
Phase 2: Pre-Audit Preparation – We prepare documentation, conduct mock audits, and train your team.
Phase 3: Audit Defence – We represent you during audits, manage document production, and provide technical defence.
Phase 4: Dispute Resolution – We resolve disputes through objection, appeal, or ADR.
Phase 5: Post-Audit Remediation – We address audit findings and strengthen controls to prevent recurrence.
Why Choose Qeeva Advisory for Tax Audit Defence
Deep Tax Audit Expertise – We have deep expertise in Nigerian tax law, audit procedures, and dispute resolution. We understand the NTA 2025 and NTAA 2025 requirements.
NRS, FIRS, and LIRS Experience – We have extensive experience representing clients before FIRS, NRS, LIRS, and other tax authorities.
Technical Defence Capability – We provide technical defence on complex issues including transfer pricing, input VAT recovery, and capital allowance claims.
Practical and Actionable – We provide practical solutions tailored to your business size, industry, and specific challenges.
Negotiation Expertise – We negotiate effectively with tax authorities to achieve the best possible outcomes.
Dispute Resolution Experience – We have experience with objections, appeals, Tax Appeal Tribunal, and ADR.
Nigerian Market Knowledge – We understand the Nigerian tax landscape, including administrative structures, audit practices, and sector-specific issues.
End-to-End Support – We provide comprehensive services from pre-audit preparation to audit defence to post-audit remediation.
Training and Capability Building – We train your team and build internal capability to withstand future audits.
Long-Term Partnership – We build lasting relationships, providing ongoing support as your business evolves and regulations change.
Confidentiality and Integrity – We treat your business and tax information with the highest level of confidentiality.
Related Services
VAT Advisory Services – Navigate tax reform, maximise recoveries, and ensure compliance.
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Tax Planning and Compliance – Minimize your tax burden while ensuring full compliance with Nigerian tax laws.
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Statutory Audit Services – Independent assurance, regulatory compliance, and stakeholder confidence.
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IFRS Advisory Services – Achieve compliance, improve reporting quality, and build investor confidence.
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Internal Audit & Controls Services – Strengthen assurance, improve controls, and drive accountability.
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Risk Management Services – Identify risks early, mitigate effectively, and protect value.
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Legal & Regulatory Advisory Services – Navigate complexity, ensure compliance, and protect your business.
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Company Formation and Post-Incorporation Services – Start right, stay compliant, and build for growth.
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Financial and Management Training Services – Build financial literacy, strengthen management capability, and drive business performance.
Learn More About Financial and Management Training Services
Deferred Tax Asset Validation Burndown – Complete guide for Nigerian businesses on deferred tax validation and compliance.
Learn More About Deferred Tax Asset Validation Burndown
Suggested Reading
VAT Under the NTA 2025: What Digital Platforms and Fintechs Need to Know – The NTA 2025 represents a significant shift in how digital platforms and fintechs are taxed in Nigeria.
VAT & Nigeria 2025 Tax Reforms: Key Changes and Implications for Businesses – This article examines Nigeria’s 2025 VAT reforms, highlighting key changes, compliance rules, and business impacts across sectors.
Common Accounting Errors That Affect Profitability in Nigeria – Accounting errors quietly drain profits, attract penalties, and limit growth.
Preparing a Business for External Audits in Nigeria – External audits can be daunting, but with the right preparation, they become an opportunity to demonstrate your business’s financial integrity.
Deferred Tax Asset Validation Burndown: Complete Guide for Nigerian Businesses – Deferred tax asset validation is a critical financial reporting discipline.
Frequently Asked Questions (FAQ)
1. What is a tax audit?
A tax audit is an examination of your tax returns and supporting records by a tax authority to verify compliance with tax laws. Audits may be desk reviews, comprehensive audits, or investigations.
2. Why are tax audits increasing in Nigeria?
Tax audits are increasing due to expanded powers under the NTAA 2025, digital enforcement tools (TaxPro-Max, e-invoicing), cross-referencing of databases, and government revenue needs.
3. What triggers a tax audit?
Common triggers include bank data mismatch, VAT/income tax mismatch, late or missed filings, PAYE petitions, unexplained transactions, transfer pricing issues, and input VAT claims without documentation.
4. What should I do when I receive an audit notification?
Do not ignore it. Contact us immediately. We help you respond appropriately, understand the scope, and prepare your defence.
5. Can I handle a tax audit myself?
While you can represent yourself, experienced representation makes a decisive difference. Auditors are trained professionals; having expert representation ensures your rights are protected and your position is defended effectively.
6. What are the penalties for tax non-compliance?
Penalties include ₦100,000 for the first month of late filing and ₦50,000 for each subsequent month for VAT; ₦50,000 for failure to register; ₦50,000 for failure to maintain records; and 10% of unremitted tax plus interest at the CBN rate for failure to remit. E-invoicing non-compliance penalties are higher.
7. What is the VAT-capital allowance linkage?
Under section 21(p) of the NTA 2025, VAT must be charged and paid on all taxable supplies before the underlying expense can qualify as allowable for income tax purposes. For capital assets, failure to charge VAT or pay import duty renders the asset ineligible for capital allowances.
8. How do you defend input VAT claims?
We demonstrate the link between input VAT and taxable supplies, provide supporting documentation, and explain the basis of the claim under the NTA 2025.
9. What is transfer pricing and why is it audited?
Transfer pricing refers to pricing of transactions between related parties. Tax authorities audit transfer pricing to ensure transactions are at arm’s length and profits are not shifted to low-tax jurisdictions.
10. Can I challenge a tax assessment?
Yes. You can file an objection with the tax authority, and if unresolved, appeal to the Tax Appeal Tribunal. We support objection preparation, appeals, and ADR.
11. What is voluntary disclosure?
Voluntary disclosure is proactively disclosing past non-compliance to tax authorities. It can reduce penalties and demonstrate good faith.
12. Do you represent clients before the Tax Appeal Tribunal?
Yes. We represent clients before the Tax Appeal Tribunal and support litigation where required.
13. Do you serve businesses outside Lagos?
Yes. While our head office is in Ikeja, Lagos, we serve businesses across Nigeria. Our tax audit defence services are available to clients regardless of location.
14. How do I get started?
Contact us to schedule your free consultation. We’ll discuss your tax audit defence needs, assess your situation, and provide recommendations for how we can help.
Contact Us
Prepare with confidence, defend with expertise, and protect your business. Let us build a partnership that strengthens your tax position.
Schedule Your Free Consultation to discuss your tax audit defence needs and explore how we can help.
Phone: +234 802 320 0801, +234 807 576 5799
Email: info@qeeva.com
Address: 5, Ishola Bello Close, Off Iyalla Street, Alausa, Ikeja, Lagos, Nigeria
Business Hours: Monday to Friday, 8:00 AM – 6:00 PM WAT
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