Section 73 Nigeria Tax Administration Act 2025

Section 73 of the Nigeria Tax Administration Act 2025 is about Issuance of advance rulings. It provides as follows:

(1) Without prejudice to any provision of this Act, advance ruling may be issued for the purpose of clarity, consistency and certainty regarding the interpretation and application of any tax law that does not constitute an amendment or replacement of the law.

(2) The relevant tax authority may –
(a) make an advance ruling on any provision of a tax law, administration, precedence and policies ; and
(b) issue an advance ruling upon application by a taxable person within 21 days of the receipt of the application or give reasons in writing for
inability to issue such ruling.

(3) An advance ruling may be issued in the prescribed form and manner and shall be signed by an authorised officer of the relevant tax authority and may contain –
(a) a statement on whether the ruling is applicable generally or limited
to the taxpayer ;
(b) the name, Tax ID and postal address of the taxpayer ;
(c) the relevant statutory provisions or legal issues addressed in the ruling ;

(d) any assumptions made or conditions imposed by the relevant tax
authority in connection with the validity of the ruling ; and
(e) the period for which the ruling is valid.

(4) An application for advance ruling shall be made in the prescribed form and manner by a person who is a party to any tax related issue or transaction, or by two or more parties to a tax related issue or transaction.

(5) An application shall contain –
(a) the name, Tax ID, postal address, email address and telephone number of the taxpayer;
(b) a complete description of the tax issue or transaction in respect of
which the ruling is sought, including its financial implications, if any ;
(c) a complete description of the impact the issue or transaction may have on the tax liability of the taxpayer or any connected person in relation to the issue or transaction ;

(d) details of any ongoing audit, previous correspondence and decisions
of the relevant tax authority on the issue ;
(e) the relevant statutory provisions or legal basis relied on by the applicant ;
(f) the reasons why the taxpayer believes that the proposed ruling
should be granted ; and
(g) a written statement on whether or not the matter is before any tribunal or court of competent jurisdiction.

(6) The relevant tax authority may request additional information from an applicant.

(7) Where necessary, the relevant tax authority shall provide an applicant with a reasonable opportunity to make representations or provide clarifications.

(8) An applicant may withdraw an application at any time before a ruling is issued.

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