The recent and drastic fall in oil
prices in the global market has hit hard on oil revenue dependent nations,
Nigeria inclusive. Thus, this has led the Government to create budgetary
policies seeking to resort to other sources of revenue, taxation being at the
forefront. However, if the Nigerian government is determined to increase its
tax revenue base, then certainty of laws governing corporate taxation of both
Nigerian and foreign companies carrying on business in Nigeria has to be at the
premium.
While a Nigerian company is taxable on
its worldwide income, a non-resident entity is liable to tax in Nigeria on its
profit attributable to the business or trade carried on in Nigeria. The issue of
taxation of foreign unincorporated companies in Nigeria has often stirred up
legal controversy.