NAUJOPL 1 (1) 2024

TAX AVOIDANCE AND EVASION IN NIGERIA: A CRITICAL EXAMINATION OF THE

LEGAL FRAMEWORK*

Abstract:
There is no functional government all over the world that does not impose tax on its people as means
of revenue generation. However, some corporate bodies make dubious efforts to avoid and evade
payment of taxes in their business transactions, thereby creating the problem of economic instability.
The study, therefore, responds to the problems of inadequate tax revenue and tax laws that allow tax
avoidance and evasion thrive. This paper critically examines the legal framework for tax avoidance
and evasion in Nigeria, highlighting gaps and weaknesses in tax laws and regulations. Using the
Qualitative Research Approach, it examines different legal frameworks on tax and taxation; while using
the Analytic Method to highlight the concept of tax avoidance and evasion, their differences, and the
legal provisions in Nigeria. The paper also explores the challenges faced by tax authorities in
combating tax evasion and avoidance, including inadequate legislation, ineffective enforcement, and
corruption. Recommendations for reform are provided to strengthen the legal framework, improve tax
compliance, maximum tax utilization for optimal economic sustainability in Nigeria.

Key words: Tax, Tax Avoidance, Tax Evasion, Legal framework, tax administration

1.0. Introduction:
Tax is a contract between the government and its people. This contract propels the people to demand
better governance from their leaders and places a burden on the leaders to provide purposeful leadership
and development.1 Tax and taxation laws neither originated in Nigeria nor is it a contemporary practice.
It has existed since humanity started experiencing one form of governance and civilization or another.
A typical voyage into taxation history reveals that the practice of taxing utilizable goods and services
started in ancient Egypt. In other words, the origin of taxation dates back to ancient civilizations, with
evidence of taxation found in ancient Egypt, Greece, and Rome. 2In ancient Egypt, taxation was used to
fund public works and military campaigns. 3 The Egyptians levied taxes on land, labor, and goods. 4In
ancient Greece, taxation was used to fund public services and infrastructure5. The Greeks levied taxes
on land, property, and trade.6In ancient Rome, taxation was used to fund military campaigns and public
works7. The Romans levied taxes on land, property, and trade. 8 Therefore, taxes were levied for smooth
administration of empires and kingdoms in ancient civilizations. Today, the purpose of taxing has not
shifted completely from that which it was designed to accomplish in ancient times. However, due to
complexities in modern governance taxation has acquired a complicated nature requiring clear
legistration to avoid incidents by which persons and corporate organizations feel unduly taxed without
commensurate wealth creation and provision of public goods and infrastructural amenities.

*
UMENWEKE, Meshach Nnama, LL.B, BL, PhD, FICM,ACTI, Professor of Law and Former Dean, Faculty
of Law, Nnamdi Azikiwe University, Awka, Anambra State. E-mail: mn.umenweke@unizik.edu.ng Tel:
08037090048
1
D A Agbu & J O Onoja, "Examination of the Legal Framework on Tax Avoidance and Evasion under the
Personal Income Tax" International Journal of Comparative Law and Legal Philosophy (IJOCLLEP) 5 (3)
(September, 2023),p.137
2
S Webb. A brief history of taxation. Taxation Magazine, 10(2), (2018), p. 12.
3
A Mann. Taxation in ancient Egypt. Journal of Egyptian History, 10(1), (2016), p. 23.
4
A Baker. A history of taxation. Routledge, (2017) p. 15.
5
G Kiros. Taxation in ancient Greece. Journal of Economic History, 15(1), (2019), p. 30.
6
C Carter, The Roman Empire and taxation. Journal of Ancient History, 10(2), (2018), p. 40.
7
E Lafe, Taxation in ancient Rome. Journal of Roman Studies, 10(1), (2017), p. 25.
8
J Temple. Roman Taxation and trade. Journal of Ancient Trade, 15(1), (2019), p. 35.

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UMENWEKE: Tax Avoidance and Evasion in Nigeria: A Critical Examination of the Legal Framework
In recent times, legal cases have existed which showed corrupt tendencies of government establishments
to tax firms without commensurate provisions of basic amenities. In Cadbury Nigeria Plc v. Federal
Board of Inland Revenue9, the court held that the taxpayer was entitled to a refund of excess taxes paid,
as the government failed to provide basic amenities such as roads and electricity. Again in Nigerian
Bottling Company Plc v. Federal Inland Revenue Service10, the court held that the taxpayer was not
liable to pay taxes on its fixed assets, as the government had failed to provide basic amenities such as
water and electricity. In Unilever Nigeria Plc v. Federal Board of Inland Revenue11 the court maintained
that the taxpayer was entitled to a tax exemption, as the government had failed to provide basic
amenities such as roads and infrastructure.

In each of the above cases, we discover that the court had tried to curtail the excesses of government
establishments in taxing corporate businesses without commensurate provisions of basic amenities
which clearly indicates that tax serves a contract between government and the governed. When
government fails to deliver their promises for which the tax is levied, then taxed entities have the moral
and legal rights to approach the court for adjudication and interpretation. On the other hand, government
bodies enact laws that deal with fraudulent individuals and corporations that try to avoid and evade tax
payments. But these enactments have not stopped tax avoidance and evasion. Thus, tax avoidance and
tax evasion are two distinct terms in the laws of taxation which have different legal effects but are often
misconstrued to mean the same thing.

Taxation is a crucial source of revenue for governments worldwide. However, tax avoidance and
evasion pose significant challenges to tax authorities, leading to revenue losses and undermining the
integrity of the tax system. Nigeria is no exception, with tax evasion and avoidance estimated to cost
the country billions of naira annually. 12 Hence, the paper is written to address the phenomenon of
taxation in Nigeria, underscoring the dynamics of tax avoidance and evasion and providing necessary
legal frameworks to arrest this challenge.

1.1 Conceptual Clarification

Meaning and its creation is the most fundamental function of language as a vehicle of communication 13.
The quest for clarity and meaningfulness has occupied the attention of any significant philosopher of
every age. Confucius was in great pains to discover that his colleagues did not speak with clarity. Hence,
he lamented:
If language is not correct, what is said is not what is meant; if what is said is not what is
meant, then what ought to be done remains undone; if this reminds undone moral and arts
will deteriorate, justice will go astray... Hence, there must be no arbitrariness in what is
said. This matters above everything.14

Given the preeminence of language clarification as highlighted by Confucius we begin the research
with the conceptualization of the terms: Tax avoidance and Tax evasion.

9
Cadbury Nigeria Plc v. Federal Board of Inland Revenue, (2010) 10 NWLR (Pt. 1201) p.347
10
Nigerian Bottling Company Plot. Federal Inland Revenue Service (2013) 12 NWLR (Pt. 1369) 211
11
(2015) 15 NWLR (Pt. 1481) 142.
12
FIRS Annual Report and Statement of Accounts, (2020), p. 12.
13
B Mondin. Philosophical Anthropology. Trans. Myroslaw A. Cizdyn, Rome: Urban University Press,
2007).p.136
14
Confucius, Analects XIII, 3, tr. Legge, quoted in Silvano Borroso, The Art of Thinking. ( Nairobi: Pauline
Publications, 2009),p.63

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1.1.1. Tax Avoidance
Tax avoidance implies the legal utilization of tax laws to minimize tax liability 15. According to Harris,
tax avoidance involves using tax exemptions, deductions, and credits to reduce tax payments. 16 Tax
avoidance is different from tax evasion, which involves illegal activities to evade tax. 17As noted by
James and Nobes, "Tax avoidance is the use of tax laws to reduce tax payments, whereas tax evasion is
the illegal non-payment of taxes."18In the words of Harris, "Tax avoidance is the legal exploitation of
tax loopholes to minimize tax liability."19

Put more simply, tax avoidance occurs when individuals or businesses use legal methods to reduce the
amount of taxes they have to pay. This is different from tax evasion, which is illegal and involves not
paying taxes that are owed. An example of tax avoidance could be contributing to a retirement account,
as this can lower one's taxable income and therefore reduce the amount of taxes one owes. Another
example could be taking advantage of tax deductions, such as for charitable donations or mortgage
interest. In other words, tax avoidance is about using the tax laws to one's advantage to pay less in taxes,
while still staying within the boundaries of the law. This is an unethical practice that could minimize
revenue accruable to government bodies through taxation.

1.1.2. Tax Evasion

Tax Evasion on its own part denotes the intentional underreporting of income or overstating deductions
to reduce tax liability. It further involves the concealment of or disguising income or assets to avoid
taxation. According to Philip Harris, tax evasion is the intentional and illegal act of concealing or
misrepresenting financial information to avoid paying taxes. It involves deliberate actions to deceive
tax authorities, such as underreporting income, overstating deductions, or concealing assets. 20As
defined by the International Monetary Fund (IMF), "Tax evasion is the deliberate act of concealing or
misrepresenting information to reduce tax liability."21In the words of Smith, "Tax evasion is the illegal
act of avoiding tax payments through fraudulent means." 22

To simplify the concept, tax evasion occurs when someone intentionally avoids paying their taxes by
not reporting all of their income or by falsely claiming deductions. This is illegal and can result in
penalties or even criminal charges. For example, if someone earns money from a side job but doesn't
report it on their tax return, they are committing tax evasion. Or if someone claims expenses on their
taxes that they didn't actually incur, that is also considered tax evasion. Therefore, tax evasion is a
serious offense that can have serious consequences. To disambiguate the two-often- erroneously-
interchanged concepts, tax avoidance involves using legal means to minimize tax liability, while tax
evasion involves illegal activities to evade tax.23 Hence, tax avoidance involves lesser punishment than
tax evasion.

15
S James., & C. Nobes. The Economics of Taxation. (London: Routledge, 2017), p. 123.
16
P Harris. Tax Avoidance and Tax Evasion. Journal of Tax Research, 17(2), (2019),, p. 15.
17
OECD. Tax Avoidance and Tax Evasion. OECD Publishing, 2019), p. 10.
18
S James, & C. Nobes, op cit. , p. 125
19
P Harris, op.cit, p.18
20
P Harris, op.cit. pp. 12-20.
21
International Monetary Fund (IMF). Tax Evasion. IMF Publishing, (2018),p. 10.
22
D Smith. "Tax Evasion and Tax Avoidance." Journal of Accounting and Finance, vol. 20, no. 1, 2020, pp. 1-
10.
23
OECD, Tax Avoidance and Evasion, (2019),p. 15

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UMENWEKE: Tax Avoidance and Evasion in Nigeria: A Critical Examination of the Legal Framework
1.1.3. Tax Administration:
Tax administration is a concept which denotes the process of managing and collecting taxes from
individuals and businesses. This involves enforcing tax laws, processing tax returns, and ensuring that
everyone pays their fair share of taxes to fund government services like schools, roads, and public
safety.

In other words, tax administration also involves auditing taxpayers to verify that they are accurately
reporting their income and deductions. This helps prevent tax evasion and ensures that everyone is
contributing to the functioning of society. For any economy to experience growth, efficient tax
administration is essential for maintaining a fair tax system that benefits everyone in a society.
In Nigeria, tax administration is the duty of tax authorities such as the Federal Inland Revenue Service
(FIRS) in enforcing tax laws.

1.1.4. Compliance
This concept refers to the extent to which taxpayers comply with tax laws and regulations. Tax
compliance refers to the degree to which taxpayers fulfill their tax obligations and adhere to tax laws
and regulations 24. It involves timely filing of tax returns, accurate reporting of income, and payment of
taxes due25. By examining these fundamental concepts (variables), the topic aims to critically evaluate
the effectiveness of Nigeria's legal framework in preventing tax avoidance and evasion.

1.2 Legal Frameworks for Taxation in Nigeria

Tax avoidance and evasion is a regular phenomenon in the Nigerian business environment. It is a
dishonest act that demands revisiting existing legal frameworks to forestall their perpetual occurrences.
In several instances, individuals and corporate bodies fail to file tax returns or pay taxes owed; some
use false or misleading information to deceive tax authorities; others engage in illegal activities to avoid
tax, such as bribery or corruption. Examples of tax evasion include business owners who fail to report
cash income to avoid paying taxes, individuals who claim false deductions or exemptions to reduce
their tax bill; a company that sets up offshore accounts to hide profits and avoid taxation; taxpayers who
file false tax returns or conceal assets to avoid detection; persons who bribe tax officials to ignore their
tax obligations.

The legal framework for taxation in Nigeria is governed by various laws, including:
1.2.1 The Companies Income Tax Act (CITA). The Companies Income Tax Act (CITA) specifically
regulates the taxation of companies. Section 9 of Act defines taxable income as the profits of a company
from all sources, including business, investment, and capital gains. 26CITA provides exemptions for
certain types of income, such as dividends, interest on government securities, and capital gains on
securities27. The act allows companies to deduct business expenses, depreciation, and losses from
taxable income. 28 It imposes penalties and interest on late filing, non-payment, or underpayment of
taxes29. Also the act provides incentives for companies engaged in certain activities, such as agriculture,
manufacturing, or exportation. 30

24
J Slemrod. "Cheating Ourselves: The Economics of Tax Evasion." Journal of Economic Perspectives, vol. 21,
no. 1, 2007, pp. 25-48
25
J Alm. "Tax Compliance and Enforcement." Journal of Economic Surveys, vol. 25, no. 5, 2011, pp. 904-927.
26
Companies Income Tax Act, Cap. C21, Laws of the Federation of Nigeria, 2004, Section 9, as amended by
Finance Act 2019 (No. 13 of 2019).
27
Sections 23-25, CITA, 2004
28
Sections 26-32, CITA, 2004
29
Sections 58-60, CITA, 2004
30
Sections 61-63, CITA, 2004

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1.2.2. Personal Income Tax Act (PITA, 2004)

Another example of legal framework that regulates taxation in Nigeria which needs special mention is
the Personal Income Tax Act (PITA, 2004) with some sections and schedules amended in 2011.
According to D. A. Agbu & J. O. Onoja, Personal income tax predates the modern Nigerian state having
evolved from the pre-colonial era through the colonial era and still evolving in this post-colonial era 31.
Historically, income tax administration post-independence was first regulated by the Income Tax
Management Act (ITMA) 1961, which was later replaced by ITMA, 1979. ITMA, 1979 was repealed
and replaced by the Personal Income Tax Decree (PITD) 1993. The Act was revised in 2004 as Personal
Income Tax Act, 2004 with some sections and schedules later amended in 2011.32 The fundamental
preoccupations of the past and present Acts is the determination of taxpayers’ tax liabilities by outlining
procedures to determine gross income, allowable and disallowable deductions from income in
ascertaining taxable income, income exempted from tax, applicable marginal tax rates, exemptions,
etc. 33.

This Act specifically states how perpetrators of tax avoidance and evasion should be penalized. The
Personal Income Tax Act, Section 41(1), as amended by Personal Income Tax (Amendment) Act 2011,
Section 5, states that:
"Any person who wilfully fails to furnish any return or statement required under this Act
commits an offence and shall be liable on conviction to a fine of N500,000 or
imprisonment for a term of three years or both."34
Also section 43(1) as amended by Section 6 of the Personal Income Tax Act 2011 states
that:
"Any person who makes a false statement or return, or who fails to disclose any material
fact, commits an offence and shall be liable on conviction to a fine of N1,000,000 or
imprisonment for a term of five years or both."35

PITA in section 45(1) as amended by Finance Act 2023, Section 22 states that:
"Where a person is convicted of an offence under this Act, the court may, in addition to
any fine or imprisonment imposed, order the person to pay a sum equal to the amount of
tax which has been evaded or avoided, and also pay a penalty of 10% of the tax due." 36

1.2.3. The Value Added Tax Act (VATA)

The Value Added Tax Act (VATA), Cap. V1, LFN 2004, is a federal law that regulates the imposition
and collection of value-added tax (VAT) in Nigeria.

Section 1(1) of the Act states that:

"Value Added Tax shall be charged and payable on the supply of all goods and services
in Nigeria."37
Section 2(1) of the Act also states that:

31
D A Agbu & J O Onoja, op.cit, p.133
32
Ibid.
33
Ibid.
34
The Personal Income Tax Act, Cap. P8, Laws of the Federation of Nigeria, 2004, Section 41(1), as amended by
Personal Income Tax (Amendment) Act 2011, Section 5
35
Section 43(1) PITA 2004, Section 6 PITA (Amendment) Act 2011
36
Section 45(1) PITA 2004, Section 22 Finance Act (Amendment) 2023
37
Value Added Tax Act, Cap. V1, Laws of the Federation of Nigeria, 2004, Section 1(1): See AG, Lagos State v.
Eko Hotels Ltd & Anor (2008) All FWLR (Pt. 398) 235

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UMENWEKE: Tax Avoidance and Evasion in Nigeria: A Critical Examination of the Legal Framework
"The tax shall be charged at the rate of 7.5% of the value of the goods and services."38
While Section 3(1) states that:
"The tax shall be paid by the consumer but shall be collected by the supplier. 39"

It is pertinent to observe that VATA imposes a 7.5% tax on the supply of goods and services in Nigeria;
the tax is paid by the consumer but collected by the supplier; and finally, VATA applies to all goods
and services except those exempted by the Act.

Nevertheless, despite the provisions of these legal frameworks for tax avoidance and evasion
provisions, they are often inadequate and ineffective. According to Adegbie and Fakile, Nigeria’s tax
laws do not clearly define tax avoidance, leading to confusion and abuse. 40The existing legal
frameworks in Nigeria have been criticized for being inadequate in combatting tax avoidance and
evasion in several ways; They are:
i. There is limited enforcement powers; under the existing Legal Framework.
ii. Existence of Lacuna and Ambiguities in the Laws
iii. Inadequate and insufficient Penalties: Penalties for tax evasion and avoidance are often
insufficient to deter offenders from further commission of the offences.
iv. Limited Resources: The Tax authorities lack sufficient and adequate resources to effectively
enforce tax laws.
v. Want of Transparency: The checks in the tax laws are insufficient to track avoidance schemes.
vi. Inadequate Taxpayer Education: Taxpayers are not sufficiently educated on their tax duties,
rights obligations and privileges and reliefs, leading to unintentional non-compliance.
vii. Inadequate International/Cross-Border Cooperation: Nigeria's laws do not provide for sufficient
cross border cum international cooperation to combat cross-border tax evasion. This is serious in
cases of transfer pricing and e-commerce.
viii. Complexity: The complexities of tax laws have made it difficult for taxpayers to comply and for
authorities to enforce.
ix. Corruption: Corrupt tax administrators have made tax administration and enforcement very
difficult to implement.
x. Outdated Laws: The Nigerian tax laws are most often outdated and do not address modern tax
avoidance schemes.

These inadequacies hinder the effective combatting of tax avoidance and evasion in Nigeria, leading to
significant revenue losses for the government. These also explain why many individuals and corporate
bodies fail to pay their taxes.

1.3. Challenges Faced by Tax Authorities in Combating Tax Evasion and Avoidance
In the course of combatting tax avoidance and evasion, tax authorities confront numerous challenges.
Sanni, Ogbonna and Appah identify two most complicated ones. According to Sanni, inadequate
legislation is a clog on the wheel of tax regulation in Nigeria. 41 For Ogbonna & Appah, it is ineffective
tax law enforcement that is the fundamental challenge to effective tax regulations in Nigeria42. However,

38
² Ibid, Section 2(1), VATA, 2024
39
Ibid, Section 3(1), VATA, 2024
40
F F Adegbie, & A S Fakile, “Tax Avoidance and Tax Evasion in Nigeria: A Review of the Legal Framework”.
Journal of Law and Economic Development, 2(1), (2016), p. 8.
41
M Sanni. Tax Evasion and Avoidance in Nigeria: An Examination of the Legal Framework. Journal of Law
and Economic Development, 3(1), (2017), p. 12
42
G N Ogbonna, & E Appah, Tax evasion and avoidance in Nigeria: Challenges and solutions. Journal of
Accounting and Taxation, 10(2), (2018):p. 20.

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besides these two, we identify the following as also prominent challenges confronting taxation in
Nigeria:
i. Complexity of Tax Laws:
More often than not, tax laws are most of the times notoriously complex, ambiguous, and subject to
multiple interpretations, making it difficult for tax authorities to enforce and for taxpayers to comply.
This complexity can lead to unintended loopholes and opportunities for tax avoidance.
ii. Limited Resources and Capacity:
Tax authorities often face budget constraints, limited personnel, and inadequate training, making it
challenging to effectively monitor and enforce tax compliance, especially in the face of sophisticated
tax avoidance schemes.
iii. Sophisticated tax avoidance schemes:
Since tax avoidance operates within the confines of the law, in many cases, taxpayers and their advisors
continually develop new and complex schemes to exploit loopholes and minimize tax liabilities, staying
ahead of tax authorities' efforts to detect and prevent them.
iv. Corruption and complicity:
Corrupt is a cancer that has eaten deep into the fabric of Nigeria's corporate existence. That is, corruption
within tax authorities or complicity with taxpayers has undermined enforcement efforts, allowing tax
evasion and avoidance to persist.43
v. International cooperation and information sharing challenges:
International collaboration has become necessary for effective enforcement of tax laws. But as
circumstances may have it, tax authorities face difficulties in obtaining information from foreign
jurisdictions, making it hard to detect and address cross-border tax evasion and avoidance.
vi. Keeping pace with technological advancements:
Technological advancement is one big challenge to tax endorsement agencies as new businesses and
schemes keep emerging from the Internet. Thus, the rapid evolution of technology creates new
opportunities for tax avoidance and evasion, such as crypto currency and digital platforms, which can
be challenging for tax authorities to keep pace with.
vii. Balancing enforcement with taxpayer rights and compliance:
Tax authorities must strike a balance between enforcing tax laws and respecting taxpayer rights,
avoiding overly aggressive enforcement that might discourage compliance.
These and several other challenges confront tax enforcement agencies in their quotidian discharge of
regulation and collection of taxes. They highlight the need for tax authorities to continually adapt and
improve their strategies, tools, and international cooperation to effectively combat tax avoidance and
evasion.

1.4. Conclusion and Recommendations

The study has painstakingly examined the phenomena of tax avoidance and evasion and the legal
framework underpinning taxation in Nigeria. To enable an ebb and flow of discussion it first of all
delineated the concepts tax avoidance and evasion, highlighting their differences even though the
common masses use them interchangeably. It observed that the legal framework for tax avoidance and
evasion in Nigeria requires urgent reform to address gaps and weaknesses. Hence, the paper made the
following recommendations:
i. Clear Definition of Tax Avoidance
The Nigerian legal framework should clearly distinguish tax avoidance from tax evasion so as to above
ambiguity of any sort. This is because the lack of a clear definition of tax avoidance in Nigeria's tax
laws and regulations creates uncertainty and ambiguity, leading to difficulty in distinguishing between

43
(UNODC, 2019, p. 30)

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UMENWEKE: Tax Avoidance and Evasion in Nigeria: A Critical Examination of the Legal Framework
tax avoidance and tax evasion (illegal evasion of tax); inadequate guidance for taxpayers, leading to
unintended non-compliance; challenges for tax authorities in identifying and addressing tax avoidance
schemes etc. Hence, the Nigerian legal frameworks should provide clear guidelines and definitions of
tax avoidance.
ii.. Strengthening Tax Laws and Regulations:
There should be legislative intervention to make the rules and guidelines around taxes more strict and
effective. This could involve things like closing loopholes that allow people to avoid paying their fair
share of taxes, increasing penalties for tax evasion, or simplifying the tax system to make it easier for
everyone to understand and comply with.
iii. Regular and Continuous Update and Amendment of Tax Laws to Address Loopholes, Ambiguities
and Future Developments and Challenges
This is very crucial as the society is dynamic. There is the need for a constant review of the existing
body of laws. Therefore, regularly updating and constant review of tax laws is important to make sure
that the tax system is fair and everyone is paying their fair share.
iv. There is the need for Tax Payer Education, Awareness and Enlightenment
Tax administration is not all about tax collection and enforcement. The tax payer ought to be enlightened
to understand the essence of tax payment. This would instill voluntary compliance and willingness to
pay the tax voluntarily. Tax education would even encourage the use of the self-assessment procedure
to pay taxes even before the tax is demanded. This would create an avenue for more understanding of
the tax laws by the tax payers. This would enable compliance and consistency in the payment of taxes,
which would in turn lead to more revenue generation for the government.
v. Collaboration between Lawmakers and Tax Administrators:
This is necessary because this would create and enable a feedback mechanism wherein the tax
administrator and agents takes the feedback of the tax laws enacted to the law makers. This synergy
would give room for updating and development of the tax law regime.
vi. Transparency in the collection and Utilization of Tax Money
This includes budget monitoring and the review of tax monies collected from tax payers. Transparency
in the system would give room for this tax payers act to see where the tax monies are going and hold
the government and the operators accountable to the monies they collect as tax from the people. A trust
relationship would be built between the tax payer and the tax administrator.
vii. Foster international cooperation to address cross-border tax avoidance.
The Nigerian Tax Administration should through the government of the day foster international
cooperation between Nigeria and friendly and trading countries to address the issue of cross border tax
avoidance and evasion.

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