Paying disputed tax while you appeal
Whether a Nigerian business must pay tax while its objection or Tax Appeal Tribunal appeal is pending, and how to record disputed payments.
By Achekam · · 4 min read · For Running a business businesses in Nigeria
"We're disputing it, so we don't have to pay yet." It is one of the most expensive assumptions a Nigerian business can make about tax. Disputes take time, and the rules on what must be paid while one runs are stricter than many owners expect.
This article explains what the Nigeria Tax Administration Act, 2025 and the Tax Appeal Tribunal say about paying during an objection or an appeal, how a Tribunal decision is enforced, why interest matters while you wait, and how to record payments so that, whatever the outcome, your books and your evidence are straight.
During an objection: pay what you don't dispute
The first stage of most disputes is an objection to the assessment. Under the Nigeria Tax Administration Act, 2025, a taxable person who disputes an assessment must deliver a written notice of objection, stating its grounds, to the relevant tax authority within 30 days from the date of service of the disputed notice of assessment. If the authority does not respond within 90 days, the objection is upheld.
Section 49(3) of the Act is the part that answers the payment question at this stage: tax not under objection must still be paid. The objection itself has to state the profits, income and tax you admit, alongside the issues in dispute and their values. Whatever you admit is due, objection or not.
In practice, that means splitting the assessment in two from the start:
- the admitted part, which you pay on time and record like any other tax payment;
- the disputed part, which the objection covers.
A business that pays nothing because it disagrees with part of the bill has turned a narrow dispute into a wider default.
After a Tribunal decision: pay within one month
If the objection does not settle things, the dispute can go to the Tax Appeal Tribunal. The Tribunal's FAQ is direct about payment after it decides: even while an appeal is pending, tax must be paid in accordance with the Tribunal's decision within one month of notification of the amount payable.
So appealing further does not pause the obligation. The Tribunal's FAQ says a person dissatisfied with a Tribunal decision may appeal on a point of law to the Federal High Court by giving written notice to the Secretary to the Tribunal within 30 days after the decision was given. The payment clock and the appeal clock run side by side; filing the appeal does not stop the first.
The Tribunal explains its procedures, including appeals and enforcement, on its frequently asked questions page.
How a Tribunal judgment is enforced
According to the same FAQ, a Tribunal judgment is enforced as a Federal High Court judgment once it is registered with that court's Chief Registrar. A Tribunal decision in the authority's favour is therefore not a recommendation; once registered, it carries the weight of a court judgment.
Interest while you wait
The NRS says interest and additional charges apply to taxes unpaid after the deadline. A dispute does not freeze that. If the business holds back tax it later turns out to owe, the bill at the end includes what accrued in the meantime.
That is the financial case for paying the admitted part promptly, and for paying a Tribunal-decided amount within the month even while appealing. If you win, the question becomes recovering what you paid. If you lose, you have avoided interest on the part you already paid.
Recording disputed payments
Every payment made during a dispute should be easy to identify later, because the outcome may mean some of it comes back.
In Achekam, a Nigerian tax payment is recorded with the authority's own reference and receipt, an RRR or DIN. Achekam never generates a payment reference, and a second person confirms each payment. RRR and DIN formats are not validated, so the confirming check against the receipt is the real control.
For a dispute, add your own discipline on top:
- record the admitted payment and any Tribunal-ordered payment separately, never combined;
- in the description, name the assessment, the tax year and whether the payment is admitted tax or paid under a decision;
- file the assessment, the objection, the Tribunal decision and each receipt together.
Showing the dispute in your accounts
A tax dispute can be large enough to matter to anyone reading your accounts. Management accounts in Achekam show an income statement for a chosen period beside the period before, and a balance sheet at period end, added up from the business's own journals and exportable as PDF or CSV. The year-to-date preset starts on 1 January, not the business's own year start, so pick the dates yourself if your year ends elsewhere.
Agree with your accountant how the disputed amount should be treated in the accounts, whether as a liability, a provision or a note, and write the reasoning down. A lender reading your balance sheet should not discover the dispute from a court notice.
Cash planning for a long dispute
- On receiving the assessment, separate the admitted amount from the disputed one.
- Pay the admitted amount on time and record it with its reference.
- Estimate the disputed amount plus possible interest, and decide how much cash to set aside.
- If the Tribunal decides, plan to pay the decided amount within one month of notification, appeal or not.
- Keep every receipt and decision in one file for the dispute.
- Review the set-aside each quarter as the dispute moves.
How an appeal to the Tribunal is filed, and where, is covered in appealing to Nigeria's Tax Appeal Tribunal. The mechanics of recording each payment are in recording a Nigerian tax payment with its RRR. Talk to your adviser about the set-aside before the first deadline passes, not after.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
