Client audits and disputes begun under FIRS
What happens to a Nigerian client's tax audit, objection, appeal or advance ruling started under FIRS now the NRS has taken over, and how to review them.
By Achekam · · 5 min read · For Accountants & audit firms in Nigeria
Most tax practices in Nigeria carry a handful of long-running matters. A desk audit opened two years ago that is still waiting for a closing letter. An objection lodged against an additional assessment, acknowledged and then silent. An appeal listed at the Tax Appeal Tribunal. Every one of them began with correspondence on FIRS letterhead.
When the Federal Inland Revenue Service became the Nigeria Revenue Service, clients started asking whether those matters had died, restarted or needed to be filed again. The short answer from the NRS is reassuring. The longer answer is that a change of name is still a good moment to put every open matter through a careful review.
The NRS position: nothing restarts
Nigeria's Federal Inland Revenue Service has been rebranded as the Nigeria Revenue Service. (An official copy of the law spells it "Nigerian Revenue Service", so expect to see both forms in correspondence.)
On open matters, the NRS is explicit. Its FAQ says ongoing audits, advance rulings, objections, appeals and disputes started under FIRS continue under the NRS without restart or revalidation. A client does not have to lodge its objection again or reapply for a ruling, and the NRS does not treat the change as wiping out work already done.
The NRS frequently asked questions cover this along with the other practical consequences of the move from FIRS, and the page is worth sending to any client who is worried that the change has reset their case.
Registrations and numbers carry over
The same FAQ says taxpayers do not need to re-register or obtain new Tax Identification Numbers, because all registrations, TINs and records issued under FIRS remain valid and migrate to NRS systems.
For the firm, that means the identifiers on existing files remain the right ones. It does not mean every system has caught up. When correspondence on an old matter arrives from the NRS, check that it quotes the same reference and identifier as the FIRS-era file, and raise any mismatch promptly rather than letting two records of the same matter run in parallel.
Advance rulings and the new guidelines
An application for an advance ruling made under FIRS continues under the NRS. The NRS describes an advance ruling as a binding decision by the tax authority on how tax law applies to a specific transaction, applied for in the prescribed form, with a response due within 21 days.
The NRS Tax Guides page now publishes Advance Ruling Guidelines among its current guidelines and information circulars. For a pending FIRS-era application, read those guidelines and consider whether the application, as lodged, still contains what the NRS now expects. If it does not, supplementing it may be wiser than waiting.
Re-checking deadlines on matters in progress
The real risk in a transition is not that a matter restarts, but that a deadline is missed because everyone assumed nothing had changed. Go through each open matter and ask what the next deadline is, what rule sets it and whether the client has been told.
Achekam computes objection and appeal deadlines for Nigerian assessments from the approved administration rule, and sets them to the end of the day in Africa/Lagos time. Its filing calendar leaves out any deadline whose rule is still awaiting approval or contested, and says why, rather than showing a date it cannot stand behind. Treat a missing date in the calendar as a prompt to calculate and diarise the deadline by hand, not as a sign there is none. The deadlines themselves are explained in objection deadlines in Nigeria and Kenya.
One further limit is relevant to old matters. Achekam holds no Nigerian tax rule for periods before 1 January 2026 and refuses to compute those periods. Most FIRS-era audits and objections concern earlier years, so any recomputation of the tax in dispute belongs in the firm's own working papers, prepared under the law that applied to that period.
Keeping each matter's trail in one place
A dispute that has run for years usually has its papers in several places: a partner's inbox, a shared drive, a box file in the client's office. Bring them together.
In Achekam's Document Centre each client has its own folder, where staff upload files and folders, keep versions, tag them, and archive or restore them with a reason. For each open matter, create a sub-folder holding the original assessment or audit notice, every letter exchanged, the objection or appeal as lodged, and a short chronology. Tag the folder with the matter type, and the next person to pick up the file will not have to reconstruct the history.
Where the matter leads to a return being amended or a new return filed, staff can open the client's Nigerian tax profile in the Revenue Service Centre and start the return there, with preparation, review and approval done by different people.
A review of every open FIRS-era file
Run this review once, now, for every client:
| Check | Why |
|---|---|
| List every audit, objection, appeal, ruling application and dispute open at the change | You cannot manage what you have not listed |
| Confirm each one is on the NRS's records under the same reference | Migration should carry it over; confirm it did |
| Identify the next deadline and the rule that sets it | Deadlines keep running through a change of name |
| Diarise any deadline Achekam's calendar leaves out | The calendar omits dates whose rule is not approved |
| Collect all correspondence into the client's folder | One trail, one place |
| Tell the client the status in writing | Clients worry about what they have not been told |
Where the firm acts for clients on the NRS's systems, make sure the people handling these matters have their own adviser access rather than a shared login, as explained in working on clients' Rev360 profiles.
Ask each tax manager for a list of open FIRS-era matters by Friday. Put them into one schedule, add the next deadline for each, and send every affected client a short letter confirming that its matter continues and what happens next.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
