Tax Appeal Tribunal says withholding tax is due on dividends from gas profits
January 2015
In brief
The Tax Appeal Tribunal (TAT) has ruled in favour of the Nigerian tax authority to levy withholding tax
on dividends paid out of gas profits by an upstream petroleum company.
The judgement takes a simple view of a rather complex provision of Sections 60 and 11 (2) of the
Petroleum Profits Tax Act (PPTA) and Sections 80 and 9(1) (c) of the Companies Income Tax Act (CITA).
A more in-depth analysis will be required in the future to conclusively resolve the issue.
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