To appeal a Nigerian tax assessment: 1) File Notice of Objection with FIRS within 30 days. 2) FIRS reviews for 60 days. 3) If rejected, appeal to Tax Appeal Tribunal within 30 days (deposit 50% of disputed tax). 4) TAT decides within 90 days. 5) Further appeals go to Federal High Court, then Court of Appeal. Valid grounds include calculation errors, wrong rates, disallowed deductions, or procedural violations.
Tax Appeal Guide for Nigeria
How to challenge FIRS assessments, object to findings, and navigate the Tax Appeal Tribunal
How do I object to a Nigerian tax assessment?
Within 30 days of receiving an assessment, send a formal Notice of Objection to FIRS. State your grounds (e.g., calculation error, wrong deductions) and attach supporting documents. FIRS has 60 days to respond. If they reject or don't respond, you can appeal to the Tax Appeal Tribunal within 30 days, but must deposit 50% of the disputed amount first.
Appeal Process Overview
Notice of Objection to FIRS
FIRS Review (60 days)
Notice of Appeal to TAT
TAT Hearing
Federal High Court (if needed)
Court of Appeal
Valid Grounds for Appeal
Critical Deadlines
Missing these deadlines can forfeit your right to appeal. Mark them in your calendar!
50% Deposit Requirement
Before TAT will hear your appeal, you must deposit 50% of the disputed tax amount or provide acceptable security (bank guarantee, property, etc.).
Exception: You can apply to waive or reduce this requirement if you can demonstrate financial hardship or that the assessment is manifestly excessive.
About the Tax Appeal Tribunal
Composition
- • Chairman (legal background)
- • 4 other members (tax/accounting experts)
- • Decisions by majority
- • Located in each geopolitical zone
Powers
- • Confirm, reduce, or set aside assessments
- • Award costs to either party
- • Order refunds with interest
- • Decisions binding unless appealed
Documents for Your Appeal
Frequently Asked Questions
How do I appeal a tax assessment in Nigeria?
First file a Notice of Objection with FIRS within 30 days of the assessment. If rejected or not resolved within 60 days, file an appeal with the Tax Appeal Tribunal within 30 days. The TAT has 90 days to decide.
How much does it cost to appeal a tax decision?
Filing at TAT costs about ₦10,000-₦20,000 plus stamp duties. If you engage a lawyer, expect ₦200,000-₦1,000,000+ depending on case complexity and the amount in dispute.
Can I appeal without paying the disputed tax?
You must deposit 50% of the disputed tax (or provide security) before TAT will hear your appeal. This is to prevent frivolous appeals and ensure collection if you lose.
What are grounds for appealing a tax assessment?
Valid grounds include: incorrect calculation, wrong tax rate applied, disallowed legitimate deductions, assessment based on wrong facts, procedural errors, or constitutional violations.
How long does a tax appeal take?
TAT should decide within 90 days. Federal High Court appeals take 6-18 months. Court of Appeal can take 1-3 years. Overall, a contested case may take 2-5 years through all levels.
Prevent Tax Disputes
Accurate tracking and timely filing reduce the risk of disputed assessments