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The short answer
Under section 41 of the Nigeria Tax Administration Act 2025, you object by written notice delivered to the tax authority within 30 days of being served the assessment, stating the disputed items with their amounts, the correction you want and the tax you accept. The authority must respond within 90 days or the objection is upheld; if you still disagree you can appeal to the Tax Appeal Tribunal within 30 days, and complaints about how officials handled you can go to the Office of the Tax Ombud.
Before you object: read the notice
A notice of assessment must be served on you, by registered post, courier or electronic means, and must set out where to pay and your rights (Nigeria Tax Administration Act 2025, or NTAA, s.40). Note three things straight away: the date you were served, the tax year and the amount. The date of service starts the 30-day clock.
Check whether it is a self-assessment you filed being accepted, an additional assessment (which the authority may raise within six years under s.36), a best-of-judgement assessment because no return was filed (s.35), or a deemed-profit assessment on a percentage of turnover (s.38). The reason for the assessment shapes your grounds.
Step 1: file a valid objection within 30 days
Section 41(1) lets a taxable person who disputes an assessment apply for its revision by "a written notice of objection delivered in person, by courier service or via electronic means". Section 41(2) says it is valid only if it is delivered within 30 days of service and contains the grounds, namely:
- the specific issues disputed or errors observed, with their monetary values;
- the amendment you want made to resolve the dispute or correct the error;
- the justification for the amendment;
- the profits, income or value of transactions you admit for the period; and
- the amount of tax you admit, or a statement that no tax is admitted.
A letter that only says "we disagree" is not a valid objection. Attach the evidence: accounts, invoices, bank statements, WHT receipts, payroll schedules. Keep proof of delivery: a stamped acknowledgement copy, the courier waybill or the portal submission receipt.
Missed the 30 days?
Section 41(3) allows the authority to extend the time "for any satisfactory and good cause shown". Ask in writing, explain why, and file the objection with the request. Do not assume it will be granted.
Step 2: pay what you do not dispute
Objecting does not freeze everything. Under s.49(3), collection of the disputed tax is held in abeyance until the objection or appeal is decided, but you must pay the tax that is not the subject of the objection. The amount you admitted in your objection is therefore payable now. Once the dispute is decided, the revised tax is due within 30 days of the new notice (s.49(4)).
Step 3: the authority reviews
The authority may ask for more particulars, require books and documents, or summon a person to give evidence (s.41(4)). Respond on time and in writing. If you agree a figure, the assessment is amended and a revised notice served (s.41(5)).
Section 41(6) is the rule that protects taxpayers: "The relevant tax authority shall respond to the objection notice within 90 days, otherwise the objection of the taxpayer shall be upheld." Diary the 90th day from delivery. If it passes with no response, write to the authority referring to s.41(6).
Step 4: appeal to the Tax Appeal Tribunal
If the authority treats your objection as invalid, or you cannot agree, you can appeal (s.41(7)). The Tax Appeal Tribunal (TAT) is established by the Joint Revenue Board of Nigeria (Establishment) Act 2025 and has jurisdiction over disputes under the Nigeria Tax Act, the NTAA and any federal or state tax law (s.29).
- Time limit: within 30 days of the assessment, demand notice or decision appealed against (Second Schedule, para 2(2)).
- Form and fee: as prescribed by the Tribunal; check the current fee with the TAT registry.
- Late appeals: the Tribunal may hear one after 30 days if satisfied there was sufficient cause (para 2(3)).
- No appeal: the assessment becomes final and conclusive and the authority may add interest and penalties (para 2(4)).
Beyond the Tribunal
Appeals from the TAT go to the Federal High Court on points of law, by notice to the Tribunal's Secretary within 30 days of the decision (JRB Act, Second Schedule, para 10). The NTAA adds that a taxpayer appealing from the Tribunal to the High Court must first pay 20% of the disputed amount into a court-designated account as security (s.41(8)). Further appeals go to the Court of Appeal and the Supreme Court (s.41(9)).
Where the Tax Ombud fits
The same 2025 Act creates the Office of the Tax Ombud. It reviews complaints about tax officials and authorities and resolves them by mediation or conciliation, and it may not charge a fee (s.41 of the JRB Act). It cannot determine a tax liability or issue an assessment, and it cannot take up a matter already before a court or tribunal (s.43). You may complain only where the issue is unresolved by the agency concerned, and anonymous complaints are not entertained; the Office is to investigate within 14 days of receipt, extendable by seven (Third Schedule). Use it for conduct and process problems: an objection ignored, a refund stuck, an official demanding cash. Our guide how to complain to the Tax Ombud has the detail.
Timeline at a glance
| Stage | Deadline | Source |
|---|---|---|
| Objection | 30 days from service of assessment | NTAA s.41(2) |
| Authority's response | 90 days, or objection upheld | NTAA s.41(6) |
| Appeal to TAT | 30 days from decision | JRB Act, Sch. 2 para 2(2) |
| Appeal to Federal High Court | 30 days from TAT decision, 20% security | JRB Act para 10; NTAA s.41(8) |
Where Pryme fits
Objections are won on records. A Pryme Business Account gives you statements you can download, and the Finance agent can assemble supporting schedules for your adviser to review. See also what to expect in a tax audit. This article is information on the law, not legal or tax advice; for large sums, use an accredited tax agent.
Questions people ask
How many days do I have to object to a tax assessment in Nigeria?
30 days from the date the notice of assessment was served, under NTAA 2025 s.41(2). The authority may extend this for good cause.
What happens if FIRS or NRS does not reply to my objection?
Under NTAA s.41(6), if the authority does not respond within 90 days, the objection is upheld.
Do I have to pay tax while my objection is pending?
You must pay the part you do not dispute. Collection of the disputed portion is held in abeyance until the objection or appeal is decided (s.49(3)).
What is the time limit to appeal to the Tax Appeal Tribunal?
30 days from the assessment, demand notice or decision, under the Joint Revenue Board Act 2025, Second Schedule. Late appeals need sufficient cause.
Sources
- Nigeria Tax Administration Act 2025 (gazette copy) · accessed Oct 2026
- Joint Revenue Board of Nigeria (Establishment) Act 2025 · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.