Objecting to a tax assessment in Nigeria or Kenya
The time limits for objecting to a tax assessment in Nigeria and Kenya, how far back each authority may assess, and how Achekam works out the dates.
By Achekam · · 4 min read · For Accountants & audit firms in Nigeria, Kenya
An assessment arrives at a client's office, sits in a pile of post or an unread inbox, and reaches the firm a fortnight later. In Nigeria and in Kenya, that fortnight may be half the time the client had to object. Miss the window and the argument about the tax becomes an argument about whether the client may argue at all.
Both countries give the taxpayer the same period to object, but they differ on what happens next and on how far back the authority can go. This article sets out the rules at the time of writing and explains how Achekam computes the deadlines, including when it deliberately leaves a date off the calendar.
Nigeria: the objection window and the NRS's reply
Under the Nigeria Tax Administration Act 2025 s.41, a Nigerian taxpayer has 30 days from service to object to an assessment. If the NRS does not respond within 90 days, the objection is upheld.
Two practical points follow. First, the clock runs from service, so the date the assessment was actually served needs to be established and recorded, not the date the firm heard about it. Second, the 90-day rule cuts in the taxpayer's favour, which makes it worth recording exactly when the objection was lodged.
What happens after an unfavourable decision is less clear. The appeal route to the Tax Appeal Tribunal within 30 days is marked uncertain in the research behind Achekam's Nigerian pack, so confirm it against the Nigeria Tax Administration Act 2025 before relying on a date.
Kenya: objection, decision and appeal
Under the Tax Procedures Act s.51, a Kenyan taxpayer has 30 days to object to an assessment. KRA must decide a valid objection within 60 days, or the objection is allowed. An appeal to the Tax Appeals Tribunal is due within 30 days of the decision.
"Valid" is doing real work in that sentence. A valid objection states its grounds and pays the undisputed tax. An objection that only says the assessment is wrong, or that is lodged without paying the part of the tax the client accepts, risks losing the protection of KRA's 60 days. The Tax Procedures Act sets out the requirements in full.
How far back each authority can assess
The window for objecting is short; the window for being assessed is long.
- Nigeria: the NRS can raise additional assessments within 6 years, and a refund must be claimed within 6 years.
- Kenya: KRA cannot raise assessments more than 5 years back, except in cases of fraud.
Neither country's research states a general record-keeping period, so do not treat these assessment limits as the period for which records may be thrown away.
| Nigeria | Kenya | |
|---|---|---|
| Time to object | 30 days from service | 30 days |
| Authority's time to respond | 90 days, or the objection is upheld | 60 days for a valid objection, or it is allowed |
| Appeal to the tribunal | Route within 30 days marked uncertain | 30 days from the decision |
| How far back assessments can go | 6 years | 5 years, except fraud |
How Achekam works out the dates
Achekam computes objection and appeal deadlines for Nigerian and Kenyan assessments from the approved administration rule. Each deadline is set to the end of the day in Africa/Lagos or Africa/Nairobi, so a firm working from another time zone sees the date as it falls in the country concerned.
The quality of the output depends on the input. Record the date the assessment was served, not the date it was scanned or forwarded. For Kenya, record the date the objection decision was received, since the appeal period runs from it.
A computed date is a ceiling, not a target. Grounds take time to write well, Kenyan objections need the undisputed tax paid, and the client has to agree to what is being said in its name. Plan to lodge well before the last day, and treat the date Achekam shows as the point after which the client's position changes for the worse.
When a deadline is missing from the calendar
Every Nigerian and Kenyan tax figure in Achekam's rule book was seeded "under review", and Achekam computes nothing from a figure until an Achekam platform administrator approves it. That applies to the administration rules behind these deadlines too.
Achekam's filing calendar leaves out any deadline whose rule is awaiting approval or is contested, and says why. An empty slot is therefore a statement, not a gap in the data: Achekam is declining to give you a date it cannot stand behind. When you see that, diary the deadline by hand from the Act.
A checklist when an assessment arrives
- Find out when the assessment was served and record that date.
- Work out the last day to object, by hand if Achekam shows no date.
- For Kenya, prepare grounds and arrange payment of the undisputed tax.
- Lodge the objection and keep proof of when it was lodged.
- Diary the authority's response period: 90 days in Nigeria, 60 days in Kenya.
- On a Kenyan decision, diary the 30 days to appeal.
- Check whether the period assessed is still within the authority's time limit.
Making the deadline somebody's job
The weakest link is usually the gap between the client receiving an assessment and the firm hearing about it. Ask Nigerian and Kenyan clients to send any assessment the day it arrives, and name one person in the firm who records the service date the same day. For small Kenyan clients' main tax, see turnover tax for small Kenyan clients.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
