The Nigerian Revenue Service (“NRS”) formerly known as the Federal Inland Revenue Service (FIRS) is actively pursuing historic freight tax liabilities against non-resident shipping companies that called at Nigerian ports, through multi-pronged enforcement strategy. These assessments, which relate to income earned from the carriage of passengers, mail, livestock, and cargo shipped or loaded in Nigeria, have long existed in Nigerian tax law but have gained renewed enforcement momentum in recent years.
The passage of the Nigeria Tax Act 2025 (the “NTA”) which repealed and consolidated the Companies Income Tax Act (“CITA”) and related fiscal legislation, does not extinguish outstanding assessments for earlier periods but reframes the legislation within which current and future claims will be determined. The successor provisions to section 14 of the CITA are now found in section 18 of the NTA, and they preserve the essential character of the freight tax regime; profits arising from
