How to Object to a Tax Assessment in Nigeria Under the 2025 Tax Laws (30 Days, Then the Tax Appeal Tribunal)

The short answer

Under the Nigeria Tax Administration Act, 2025, a taxpayer who disputes an assessment has 30 days from service of the notice to deliver a written notice of objection to the tax authority that issued it, whether that is the Nigeria Revenue Service or a state internal revenue service. The objection is only valid if it says exactly what is disputed, in naira, what should change and why, and how much tax you admit. The authority then has 90 days to respond; if it does not, section 41(6) says the objection "shall be upheld".

If the authority rejects the objection or you cannot agree, the dispute goes to the Tax Appeal Tribunal, established under the Joint Revenue Board of Nigeria (Establishment) Act, 2025. The appeal must be filed within 30 days of the decision. From the Tribunal, an appeal to the Federal High Court lies on a point of law only, and section 41(8) requires you to pay 20 per cent of the disputed amount into a court-designated account as security before that appeal is heard.

Miss the objection or appeal window and section 43 makes the assessment "final and conclusive", after which the authority can distrain your goods, land and premises (section 61). This guide takes each stage in order, with the section numbers.

Step 1: read the notice and count 30 days

Section 41(2)(a) counts the 30 days "from the date of service of the disputed notice of assessment". Service is when the notice reaches you or your registered address or email, not when you get round to reading it. Diarise day 30 the day it arrives.

Before you object, work out which of three things you are looking at:

• An assessment you disagree with on the merits (the figures, a disallowed expense, a deemed-income computation). This is what section 41 is for.
• An assessment based on your own return, where the return was wrong. Correcting the return may be faster than objecting; see how to correct a mistake on a filed tax return. Ask the authority in writing which route it wants, inside the 30 days.
• A best-of-judgment assessment raised because you filed nothing. You can still object, but the Tribunal can later order a deposit before hearing you (see step 5), and the burden of proof is yours. File the missing return with the objection.

If you are outside the 30 days, section 41(3) lets the authority extend time "for any satisfactory and good cause shown". Ask in writing, explain the delay day by day, and attach the objection itself.

Step 2: write an objection that is valid

Section 41(2)(b) is unusual. It does not just require grounds; it lists five things the notice must contain, and an objection missing any of them is not valid, which means the 30 days keep running as if nothing had been filed. The five:

1. The specific issues disputed or errors observed, with their monetary values. Not "the assessment is excessive" but "line 4, disallowed rent of N3,600,000; line 7, withholding tax credits of N410,000 omitted".
2. The amendment required to resolve the dispute or correct the error: the figure you say each line should show.
3. The justification for each amendment: the section of the Nigeria Tax Act or the evidence that supports it.
4. The amount of assessable and total profits, income or value of transactions you admit for the period.
5. The amount of tax you admit, or a statement that no tax is admitted as payable.

Attach the evidence for every line: contracts, invoices, bank statements, payroll, withholding-tax credit notes, your computation. Section 41(4) lets the authority demand particulars and books and summon witnesses on oath, so assume it will.

Delivery is in person, by courier or "via electronic means" (section 41(1)). Whatever you use, keep proof of the date: a stamped copy, the courier waybill, or the portal acknowledgement.

The practical reason to be this precise: at the Tribunal, paragraph 7(5) of the Procedure Schedule puts "the onus of proving that the assessment complained of is excessive" on you. The objection is the first draft of that proof.

Step 3: the 90-day clock on the authority

Section 41(6): "The relevant tax authority shall respond to the objection notice within 90 days, otherwise the objection of the taxpayer shall be upheld." This is the taxpayer-friendly innovation of the 2025 Act, and it only helps if you can prove the date of delivery. Keep that proof with the objection.

Three outcomes are possible inside the 90 days:

• Agreement on the amount (section 41(5)): the assessment is amended and a revised notice of the tax payable is served. That revised figure becomes final and conclusive under section 43(1)(b).
• Rejection, or a finding that the notice was invalid (section 41(7)): you "may exercise the right of appeal".
• Silence past day 90: the objection is upheld by operation of law. Write to the authority recording that fact and asking for the amended notice.

The Act sets no payment holiday during the objection. Pay the tax you admit under item 5 of the objection by the due date; the disputed balance is the subject of the dispute, and interest and penalties on a final assessment are the downside if you lose.

Step 4: appeal to the Tax Appeal Tribunal

The Tribunal sits in zones under section 23 of the Joint Revenue Board Act, with five Tax Appeal Commissioners per zone chaired by a legal practitioner of at least ten years' standing and a quorum of three (section 24). Its procedure is in the Act's Second Schedule and the Tax Appeal Tribunal (Procedure) Rules 2021.

• Deadline. Paragraph 2(2): the appeal must be filed "within a period of 30 days from the date on which a copy of the assessment, demand notice, action or decision which is being appealed against is made, or deemed to have been made". For an objection the authority has rejected, that is the date of its decision. Paragraph 2(3) lets the Tribunal hear a late appeal "if it is satisfied that there was sufficient cause for the delay"; paragraph 2(4) says that without a notice of appeal in time the assessment "shall become final and conclusive" and interest and penalties follow.
• Form and filing. The Tribunal's own guidance: Notice of Appeal on Form TAT 1, with the fee in the Second Schedule to the 2021 Rules, ten copies, filed in the zone where the dispute originates or online through the Tribunal's e-filing portal. The notice must state the grounds, the reliefs sought, the particulars of the assessment or decision, the persons affected and both parties' addresses for service. If you will call witnesses, file the witness list and sworn witness statements with the documents you rely on.
• Representation. You may appear yourself or through counsel, a chartered accountant or an adviser; a company appears through a director, officer or employee.
• Settlement window. Paragraph 6: at the first hearing the Chairman may give the parties up to 30 days to settle under the Tax Administration Act's provisions; if they do not, the case goes to trial.
• Hearing. Seven clear days' notice (paragraph 7(2)); hearings are public (7(4)); the Evidence Act applies (paragraph 8). The Tribunal may "confirm, reduce, increase or annul the assessment" (7(8)), so an appeal can make things worse. The decision is recorded in writing and a certified copy supplied on request within seven days (7(9)).
• Enforcement. A Tribunal judgment is enforced as a Federal High Court judgment once registered with the Chief Registrar (paragraph 9).

Step 5: the deposit the Tribunal can order

Paragraph 7(5) to (7) of the Schedule is where "pay now, argue later" appears in Nigerian law, and it is narrower than the folklore. The Tribunal may order a deposit only if the tax authority proves one of three things: that you failed to file the returns for the year in question, that the appeal is "frivolous or vexatious or constitutes an abuse of the appeal process", or that it is "expedient" to require security. The amount is the lesser of the tax charged on you for the preceding year and one half of the tax under appeal, paid to the tax authority before the adjourned hearing. If you do not pay, the assessment is confirmed and you have "no further right of appeal in the tribunal with respect to that assessment".

Two consequences. First, filing your returns, even late, removes the most common ground for a deposit order. Second, a deposit order is not automatic and should be argued, with last year's tax figure in hand, because the "lesser of" formula often produces a much smaller number than half the assessment.

Step 6: the courts, and the 20 per cent security

Section 41(8) of the Tax Administration Act: a taxpayer dissatisfied with the Tribunal's judgment may appeal to the High Court, "provided that it shall pay 20% of the disputed amount into an account designated by the High Court as security before the hearing of the appeal, and include the evidence of payment while filing the notice of the appeal". The Joint Revenue Board Act's Schedule adds that the appeal is on a point of law only and is started by written notice to the Secretary of the Tribunal within 30 days of the decision (paragraph 10). Further appeals go to the Court of Appeal and then the Supreme Court (section 41(9)).

Facts are therefore settled at the Tribunal. If a document matters, it has to be in the Tribunal bundle.

The Tax Ombud: a parallel route for conduct, not amounts

The Joint Revenue Board Act also created the Office of the Tax Ombud (sections 36 to 41), an independent arbiter that can review complaints about tax officials and authorities, mediate, investigate, enter tax offices, and even "institute legal proceedings on behalf of the taxpayer". It is the right address for a complaint that an officer is refusing to acknowledge an objection, demanding payment on a non-final assessment, or distraining without a demand notice. It is not a substitute for the objection and the Tribunal appeal, and it does not stop the 30-day clocks.

A worked timeline

Assume a notice of assessment is served on 2 March.

Mistakes that lose otherwise good cases

• A letter that argues but does not list. Without the five items in section 41(2)(b), the objection is invalid and the assessment becomes final on day 31.
• No proof of delivery. The 90-day rule in section 41(6) is worthless if you cannot prove when the clock started.
• Treating silence as pending. Day 91 without a response is a win under the Act; record it in writing.
• Appealing to the Tribunal at day 45. The Schedule's 30 days run from the authority's decision; a late appeal needs "sufficient cause".
• Never filing the return for the disputed year. It is the first ground for a deposit order and it shifts the whole hearing against you.
• Paying nothing. Pay the admitted tax; interest and penalties on a final assessment are calculated on the unpaid amount.
• Saving the evidence for court. The Federal High Court hears law only; the Tribunal is the last place facts can be proved.

Who this affects most

• Small companies and sole traders assessed on a best-of-judgment basis after a missed filing (how to file your taxes, how to get a TIN).
• Employees under the new PAYE rules whose employer's computation and the state revenue service's assessment differ (the new PAYE tax law, PAYE explained).
• Freelancers and digital earners assessed on bank inflows (freelancer taxes).
• Anyone coming out of an audit with an additional assessment (how to handle a tax audit, records that survive an audit).

Frequently asked questions

Can I object by email? Yes. Section 41(1) allows delivery "via electronic means" as well as in person or by courier. Keep the sent record and any acknowledgement.

What if the tax authority ignores my objection? Section 41(6) gives it 90 days; after that "the objection of the taxpayer shall be upheld". Write to the authority citing the delivery date and the subsection, and ask for the amended notice.

Do I have to pay before the Tribunal hears me? Not as a rule. A deposit can be ordered only where you did not file returns for the year, the appeal is frivolous or vexatious, or security is expedient, and then only the lesser of last year's tax and half the assessed tax (Schedule, paragraph 7(5) to (7)).

Do I have to pay before the High Court hears me? Yes. Section 41(8) requires 20 per cent of the disputed amount paid into a court-designated account before the hearing, with proof filed with the notice of appeal.

Can the Tribunal increase my assessment? Yes. Paragraph 7(8) lets it "confirm, reduce, increase or annul" the assessment.

Where do I file? In the Tribunal zone where the dispute originates, in ten copies, or through the Tribunal's online filing portal. The Tribunal has an office in each of the six geopolitical zones.

Does a complaint to the Tax Ombud stop the clock? No. The Ombud deals with the conduct of tax officials and authorities and can mediate or sue on your behalf, but the 30-day objection and appeal periods run regardless.

Sources: Nigeria Tax Administration Act, 2025 (Act No. 5 of 2025), sections 41, 43 and 61; Joint Revenue Board of Nigeria (Establishment) Act, 2025 (Act No. 6 of 2025), sections 23, 24 and 36 to 41 and the Second Schedule; Tax Appeal Tribunal, Frequently Asked Questions, citing the Tax Appeal Tribunal (Procedure) Rules 2021. Gazette texts checked 24 October 2026. General information, not legal or tax advice.