History
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The Tax Appeal Tribunal (TAT) is presently established pursuant to Section 23 of the Joint Revenue Board of Nigeria (Establishment) Act, 2025, which constitutes the current legal framework governing the Tribunal in Nigeria. The 2025 Act repealed the provisions of Section 59 and the Fifth Schedule of the Federal Inland Revenue Service (Establishment) Act, 2007, under which the Tribunal was previously established, while preserving pending proceedings and the continuity of the Tribunal through transitional provisions.
Although the Tribunal originally commenced operations pursuant to the Tax Appeal Tribunals Establishment Order, 2009, issued by the Honourable Minister of Finance and published in the Federal Government Official Gazette No. 296, Vol. 96 of 2 December 2009, its continued existence and jurisdiction are now derived from the Joint Revenue Board of Nigeria (Establishment) Act, 2025.
The Tribunal replaced the former Body of Appeal Commissioners (BAC) and the Value Added Tax (VAT) Tribunals as Nigeria's specialised tax dispute resolution body. It serves as an administrative tribunal vested with jurisdiction to determine disputes arising from the administration and enforcement of tax laws. Proceedings before the Tribunal constitute a mandatory preliminary step before the invocation of the jurisdiction of the Federal High Court in tax matters, subject to the right of appeal on questions of law.
Under Section 23 of the Joint Revenue Board of Nigeria (Establishment) Act, 2025, the Tribunal has jurisdiction to hear and determine disputes arising from the administration of the Act and other applicable tax laws enacted by the National Assembly. Its jurisdiction extends to matters arising under, among others:
* Companies Income Tax Act;
* Petroleum Profits Tax Act (where applicable);
* Personal Income Tax Act;
* Capital Gains Tax Act;
* Stamp Duties Act;
* Value Added Tax Act; and
* Any other tax law enacted by the National Assembly or otherwise brought within the Tribunal's jurisdiction by law.
Pursuant to the Tax Appeal Tribunals Establishment Order 2009, TAT is established in eight cities to cover the six geo-political zones namely: Abuja, Lagos, Ibadan, Benin, Enugu, Kaduna, Jos and Bauchi and a Coordinating Secretariat located in Abuja.
Consequently, the Tax Appeal Tribunal Chairmen and Commissioners were inaugurated on the 4th of February, 2010 while the secretariat staff resumed duties at their respective posts on July 1st. 2010 after a two-week induction training. This marked the formal take-off of the new Tax Appeal Tribunal in Nigeria. All proceedings before the Tribunal are guided by the Tax Appeal Tribunal (Procedure) Rules 2021.
Currently, TAT is Established by the Joint Revenue Board of Nigeria (Establishment) Act, 2025. Tax Appeal is an important component of the tax system and the new tax policy offers a step by step objection and appeal process which gives the complainant an opportunity to explore other dispute resolution mechanisms before gaining access to the regular court system. According to the Establishment Act, both the tax payer and relevant tax authority can initiate the appeal process. A person aggrieved by an assessment or demand notice made upon him by the Service or aggrieved by any action or decision of the Service under the provisions of the tax laws administered by the Service may appeal against such action, decision, assessment or demand notice within a period of 30 days. On the other hand, The Service, if aggrieved in relation to any person in respect of any provisions of the tax laws, can also within a period of 30 days, file an appeal at the appropriate zone of the Tribunal.
It is the expectation of all stakeholders that the establishment of the TAT would reduce the incidence of tax evasion, ensure fairness and transparency of the tax system, minimize the delays and bottlenecks in adjudication of tax matters traditional court system, improve the tax payers’ confidence in our tax system, provide opportunity for expertise in tax dispute resolution, provide avenue for effective involvement of parties, focus on facts rather than legal technicalities and promote early and speedy determination of matters without compromising the principle of fairness and equity.