Section 191 Nigeria Tax Act 2025

Section 191 of the Nigeria Tax Act 2025 is about Artificial transactions. It provides as follows:

(1) Where a relevant tax authority is of the opinion that a disposition is not given effect to, or that a transaction which reduces or may reduce the amount of tax payable, is artificial or fictitious, it may disregard any such disposition or transaction, or direct that such adjustments be made with respect to liability to tax as it considers appropriate, to counteract the reduction of liability to tax and issue an assessment or additional assessment accordingly.

(2) The provisions relating to objections and appeals under Chapter Four of the Nigeria Tax Administration Act, 2025 , shall apply to a direction made under this section.

(3) For the purpose of this section –
(a) “disposition” includes any trust, grant, covenant, agreement or arrangement; and
(b) a transaction between connected persons shall be deemed to be artificial or fictitious if, in the opinion of the relevant tax authority, the transaction has not been made at arm’s length.

[/membership]