Section 36 Nigeria Tax Administration Act 2025

Section 36 of the Nigeria Tax Administration Act 2025 is about Additional assessments. It provides as follows:

(1) Where the relevant tax authority discovers or is of the opinion, at any time, that any taxable person liable to tax has not been assessed or has been assessed at an amount less than that which ought to have been charged, the relevant tax authority may, within six years of the assessment, assess the taxable person at such amount or additional amount, as ought to have been charged.

(2) The six-year limitation period stipulated in subsection (1) shall not preclude the relevant tax authority from continuing with a tax audit and for raising additional assessment where the tax audit commenced before the expiration of the six-year limit.

(3) The provisions of this Act as to the notice of assessment, appeal and other proceedings shall apply to such assessment or additional assessment and to the tax charged.

(4) Notwithstanding the time limit specified in subsection (1), where there is a deliberate misstatement by a taxable person in connection with any tax imposed under the Nigeria Tax Act, 2025 or any other tax law, the relevant tax authority may at any time, and as often as may be necessary, assess the taxable person to such amount or additional amount as may be necessary for the purpose of making good any loss of tax attributable to the deliberate misstatement.

(5) All relevant facts shall be considered in the computation of the amount or additional amount of tax that should have been charged under subsection (1), even where such facts were not known when a prior assessment or additional assessment was made for the taxable person in the same year.

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