Objecting to a Nigerian assessment: what to include
What a Nigerian business must put in a notice of objection to a tax assessment, why the undisputed tax is paid first, and what if no reply comes.
By Achekam · · 4 min read · For Running a business businesses in Nigeria
An assessment arrives that is plainly wrong in places. Perhaps the authority has added back expenses you can document, or estimated turnover from bank credits that include loans and transfers between your own accounts. The instinct is to write back saying "we disagree". A letter like that is not much of an objection, and under the Nigeria Tax Administration Act, 2025 it may not count as a valid one at all.
The Act is specific about what an objection must contain, and the Lagos Internal Revenue Service treats one part of it as a condition of validity. This article sets out the required contents, the payment that has to accompany them, what happens if the authority stays silent, and how to assemble the objection so that it can carry the dispute as far as it needs to go.
The deadline comes first
Section 41(1) of the Act gives a taxable person who disputes an assessment 30 days from the date the disputed notice of assessment is served to deliver a written notice of objection, stating its grounds, to the relevant tax authority. The NRS describes the same window for income tax assessments and notices, and adds that the objection should attach supporting documents. The authority may extend the time for good cause, under section 41(3), but do not plan around an extension you have not been given.
The LIRS FAQ adds a warning for Lagos assessments: an assessment that is neither objected to nor paid within 30 days becomes final and conclusive, and must then be paid within 60 days.
What the notice must state
Section 41(2)(b) of the Act lists what an objection must contain. In plain terms:
| The Act requires | What it looks like in practice |
|---|---|
| The specific issues in dispute | Each item named separately: "disallowed repairs", "turnover from director's loan credits" |
| The monetary value of each issue | The amount the authority's figure differs from yours, item by item |
| The amendment you want | The corrected figure you ask the authority to adopt |
| The justification | Why your figure is right, with the documents that show it |
| The profits, income and tax you admit | The figure you accept, and the tax on it |
The last row is the one most often left out, and it matters. Admitting what is not in dispute narrows the argument to the items that are, and it sets up the payment the next section describes.
The Act's objection provisions are in the Nigeria Tax Administration Act, 2025, published on the LIRS site; section 41 covers the content, the time limit, extensions and appeals.
Pay the tax you do not dispute
Under section 49(3) of the Act, tax that is not under objection must still be paid. The LIRS FAQ goes further for Lagos: a Notice of Objection, filed on its e-Tax platform, must enclose evidence that the undisputed portion has been paid, and the FAQ reads section 41(2) as making that a prerequisite for a valid objection.
So the admitted tax is not just a figure in the letter; it is money that should leave your account before, or with, the objection. An objection sent without it risks being treated as no objection at all, with the assessment then becoming final.
The LIRS FAQ also says an objection sent after a Pre-Action Protocol Notice is out of time. If you have received one, the window has closed.
If the authority does not answer in 90 days
Section 41(6) of the Act says that if the authority does not respond to an objection within 90 days, the objection is upheld. That is a strong protection for the taxpayer, and it depends on your being able to prove when the objection was delivered. Keep the e-filing acknowledgement, the courier receipt or the stamped copy.
Where the authority does respond and you cannot agree, section 41(7) allows an appeal. The NRS says the Act gives taxpayers the right to appeal assessments and penalties, alongside the fines, interest and other consequences it sets for late filing, late payment and under-reporting.
Deadlines in Achekam
Achekam computes objection and appeal deadlines for Nigerian assessments from the approved administration rule, ending at the close of the day in Lagos time. Its filing calendar leaves out any deadline whose rule is still awaiting approval or contested, and says why. Where an entry is missing for that reason, diary the 30 days yourself from the date of service.
Keeping the assessment, notice and evidence together
An objection is only as good as the evidence behind each line of the table. Achekam's Document Centre stores files in folders that can be tagged and searched, and keeps a file's earlier versions when a new one is uploaded. Set up one folder per assessment holding:
- the notice of assessment, with the date it was served;
- the objection as sent, and proof of delivery;
- evidence of payment of the admitted tax;
- the documents supporting each disputed item;
- every later letter in either direction.
If the dispute goes on to the Tribunal, this folder becomes the core of the appeal.
Bringing in your accountant
An objection is the moment to involve your accountant, not the moment after it fails. A business can appoint its accounting firm in Achekam using the firm's Achekam address or firm code, in a role such as accountant, tax practitioner or adviser, with an access level the business chooses; the firm then accepts or declines. With access to the ledger, your accountant can build the "amount admitted" and the value of each disputed item from the books themselves.
The objection windows in Nigeria and Kenya are set side by side in tax objection deadlines in Nigeria and Kenya. If agreement cannot be reached, appealing to Nigeria's Tax Appeal Tribunal explains the next step.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
