Appealing to Nigeria's Tax Appeal Tribunal
How a Nigerian business appeals to the Tax Appeal Tribunal, what can be appealed, where and how to file, and what happens if the appeal is late.
By Achekam · · 4 min read · For Running a business businesses in Nigeria
Your objection did not settle it. The tax authority has stood by its assessment, or issued a demand you believe is wrong, and the amount is too large to simply pay and move on. The next step for a Nigerian business is usually the Tax Appeal Tribunal, a body set up to hear exactly this kind of dispute.
Appeals are procedural. The right form, in the right office, with the right number of copies, inside the time limit, matters as much as the strength of your argument. This article walks through what the Tribunal's own FAQ says about what can be appealed, where and how to file, the time limit and late appeals, and what comes after the Tribunal decides.
What can be appealed
The Tribunal's FAQ says a person aggrieved by an assessment, demand notice, action or decision of the Service under the tax laws it administers may appeal to the Tribunal.
That list is broader than many people assume. It is not only assessments. A demand notice, an action taken against the business, or a decision, such as a refusal of a claim, can be appealed too.
Two points of caution about the FAQ itself. It restates the Tax Appeal Tribunal (Procedure) Rules 2021, it does not define "the Service", and it does not mention the Nigeria Tax Administration Act, 2025. Read it as a guide to procedure, and have your adviser confirm how it applies to your dispute under the current law.
Where and how to file
According to the FAQ, an appeal is filed:
- in the Tribunal zone from which it emanates, meaning where the dispute arose;
- on Form TAT 1, in the First Schedule to the Tax Appeal Tribunal (Procedure) Rules 2021;
- with the fee prescribed in the Second Schedule;
- with ten copies of the Notice of Appeal, filed at that zone.
The FAQ says the Tribunal has offices in each of the six geo-political zones, and that appeals can also be filed online.
Ten copies sounds old-fashioned, but it is what the FAQ says, and a filing short of copies is an avoidable delay. Check with the zone office, or the online filing route, what it expects on the day.
The Tribunal sets out who can appeal, how and where to file, the fees, timelines and enforcement on its frequently asked questions page.
The 30-day limit and late appeals
The FAQ says the appeal must be filed within 30 days. It does not settle, in a way everyone agrees on, when those 30 days start: the Tribunal's FAQ and the NRS's own page on the Tribunal describe the starting point differently. Check the Procedure Rules with your adviser, and work from the earliest date that could apply.
If the deadline has passed, all is not necessarily lost. The FAQ says the Tribunal may entertain an appeal filed after the 30-day period if it is satisfied that there was sufficient cause for the delay. "Sufficient cause" is for the Tribunal to judge, so a late appeal needs a clear, honest, documented explanation. It is a fallback, not a plan.
Deadlines in Achekam
Achekam computes objection and appeal deadlines for Nigerian assessments from the approved administration rule, setting them to the end of the day in Lagos time. Its filing calendar leaves out any deadline whose rule is awaiting approval or contested, and says why.
Read that limit carefully. Because the starting point of the Tribunal's 30 days is described differently by the Tribunal and the NRS, do not treat a missing calendar entry as a missing deadline. Diary the earliest possible date yourself.
After the Tribunal: the Federal High Court
The Tribunal is not necessarily the last word. Its 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.
Two things follow. A further appeal is on a point of law, not a rerun of the facts, so the facts you prove at the Tribunal are the facts that count. And appealing does not suspend payment: the FAQ says tax must be paid in accordance with the Tribunal's decision within one month of notification of the amount payable, even while an appeal is pending. A Tribunal judgment is enforced as a Federal High Court judgment once registered with that court's Chief Registrar.
Organising your documents and your representative
The dispute file. An appeal is built on paper: the assessment or demand, the objection, the authority's response, the computations, contracts, invoices and correspondence. Document Centre in Achekam keeps files in folders you can tag and search, with earlier versions kept when a file is replaced. Make one folder for the dispute, with subfolders for the authority's documents, your submissions and your evidence, so that ten copies can be made from one clean set.
Your representative. Most businesses appeal with an adviser. In Achekam a business can appoint its accounting firm by the firm's Achekam address or firm code, as accountant, auditor, tax practitioner, payroll provider or adviser, with an access level, and the firm accepts or declines. Giving your tax practitioner direct access to the ledger and the dispute folder saves time when they are preparing the Notice of Appeal.
An appeal checklist
- Confirm what you are appealing: assessment, demand notice, action or decision.
- Diary the earliest possible end of the 30 days.
- Identify the zone the dispute emanates from.
- Prepare Form TAT 1, the fee and ten copies of the Notice of Appeal, or use online filing.
- Assemble the evidence in one folder.
- Plan for paying any Tribunal-decided amount within one month.
What an objection should contain, before any appeal, is set out in objecting to a Nigerian assessment. The objection deadlines in both countries are compared in tax objection deadlines in Nigeria and Kenya.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
