Introduction

Before committing
 to
 a 
major 
transaction, 
a 
business 
wants 
to 
know 
what
 it
 will
 pay 
in
 tax.
 An
 advance
 tax 
ruling
 (“ATR”)
 gives 
it 
that 
answer, 
in
 writing, 
from
 the
 tax 
authority 
before the
transaction 
is
 carried 
out. 
Before 
the
 Nigeria
 Tax
 Administration
 Act
 2025
 (“NTAA”),
 Nigerian
 taxpayers
 could
 obtain
 tax
 positions
 or
 rulings
 administratively,
 but
 there
 was
 no
 generally
applicable 
statutory
 framework
 conferring
 legal
 effect 
on
 those
 rulings.

Their
 force 
against 
the 
tax
 authority
 was
 therefore 
uncertain,
 and
 disputes
 over
 prior
 representations
 were
 addressed
 through
 doctrines
 such
 as
 legitimate
 expectation
 and
 estoppel,
 subject
 always
 to
 the
 governing 
tax
 statute.