On the 17th of August 2023, the Tax Appeal Tribunal sitting in Lagos allowed an appeal which questioned the legality of the Income Tax (Country-By-Country) Regulations of 2018, amongst other issues, and found the Regulations to be incompetently issued.

We offer a considered review of this judgment via our newsletter below which presents our attempt to shed more insight into the critical issues raised and decided upon in the judgment, and their implication for tax administration and governance.