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WHEN TIME MEETS TAX: LEGAL ANALYSIS OF OANDO PLC V. FIRS

  • lawhermon
  • Feb 27
  • 1 min read
The decision of the Tax Appeal Tribunal (the “TAT” or “Tribunal”) in Oando Plc v. Federal Inland Revenue Service brings into sharp focus the time of application question for tax penalties. At its core, the Tribunal had to decide whether a harsher penalty regime introduced by the Finance Act 2023 could validly apply to a default that occurred after the legislation commenced but in respect of an earlier Year of Assessment (YoA). The Tribunal’s answer hinged on a conceptual bifurcation between (i) the period in which income is earned and assessed (the taxable period) and (ii) the window in which filing obligations fall due (the compliance period).... Click below to read more
The decision of the Tax Appeal Tribunal (the “TAT” or “Tribunal”) in Oando Plc v. Federal Inland Revenue Service brings into sharp focus the time of application question for tax penalties. At its core, the Tribunal had to decide whether a harsher penalty regime introduced by the Finance Act 2023 could validly apply to a default that occurred after the legislation commenced but in respect of an earlier Year of Assessment (YoA). The Tribunal’s answer hinged on a conceptual bifurcation between (i) the period in which income is earned and assessed (the taxable period) and (ii) the window in which filing obligations fall due (the compliance period).... Click below to read more

 
 
 

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