Section 147 Nigeria Tax Administration Act 2025

Section 147 of the Nigeria Tax Administration Act 2025 is about Interpretation. It provides as follows:

In This Act —
“advance ruling” means any ruling issued by the tax authority in respect of any disputed or controversial tax matter to the taxpayers in accordance with provision of this Act, the Nigeria Tax Act, 2025, or any other tax law enacted by the National Assembly, or any written opinion or decision issued to a taxpayer by the relevant tax authority on a transaction, proposed transaction or any tax matter with a view to providing direction or clarification in accordance with the provisions of this Act ;

“agency of government” includes a Ministry, department, statutory body,
public authority or any institution of the Federal, State or Local Government;

“agreement” means mutual understanding, arrangement, undertaking,
or memorandum, between a taxpayer and any third-party which may have
tax implications ;

“assessable income” has the same meaning under the Nigeria Tax Act,
2025 ;
“assessable profit” has the same meaning under the Nigeria Tax Act,
2025 ;

“authorised officer” means any person employed in the service of the
relevant tax authority or, for the time being, performing duties in relation to tax who has been specifically authorised by the Board or the Chairman to perform or carry out specific functions under this Act, the Nigeria Tax Act, 2025, or any other tax law enacted by the National Assembly or the State House of Assembly ;

“board” means the Board of the relevant tax authorities established
under this Act ;
“book” includes any register, document or other records of information and any account or accounting record however compiled, recorded or stored,
whether in written or printed form or micro-film, digital, magnetic or electronic form or otherwise ;

“business” includes any economic activity such as trade, commerce, manufacturing, service or any activity carried out for the purpose of earning
income ;
“calendar year” means a period of 12 months commencing from 1 January and ending 31 December ;

“commencement of business” means the date that an entity carries out
its first transaction, which shall be the earlier of the date that the business or person –
(a) begins to market or first advertises its products or services for sale ;
(b) obtains an operating licence from a regulatory authority in Nigeria ;
(c) makes first sale or purchase ;

(d) executes its first trading contract after complying with incorporation
or regulatory processes ;
(e) issues or receives its first invoice ;
(f) delivers or receives its first consignment of goods ; or

(g) first renders services to its customers ;

“Commissioner” means the commissioner charged with responsibility
of finance in a State in Nigeria ;

“company” means a company as defined under the Companies and
Allied Matters Act and a corporate body that may be formed under any
other written law and includes any association, whether incorporated in or
outside Nigeria ;

“dispute” means a disagreement on the interpretation of either the relevant
facts or law or both, which arises pursuant to the issuance of an assessment,
action or decision of either the tax authority or taxpayer ;

“distrain” means to seize a taxable person’s property, goods, chattels,
bonds or other securities in order to collect and recover unpaid tax in
accordance with this Act and the Nigeria Tax Act, 2025 ;