TITLE PAGE
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DECLARATION
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CERTIFICATION
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ACKNOWLEDGEMENT
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DEDICATION
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LIST OF ABBREVIATIONS TABLE OF STATUTES
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TABLE OF CASES –
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TABLE OF CONTENTS
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ABSTRACT
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Chapter ONE

GENERAL INTRODUCTION
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1.1
BACKGROUND OF THE STUDY
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1.2
LITERATURE REVIEW

1.3
STATEMENT OF THE PROBLEM –

1.4
OBJECTIVES OF THE RESEARCH

1.6
SCOPE OF RESEARCH
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1.7
RESEARCH METHODOLOGY

1.7
JUSTIFICATION OF THE RESEARCH-

1.8
ORGANIZATIONAL LAYOUT
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Chapter TWO

HISTORICAL DEVELOPMENT OF CORPORATE TAX LAW IN NIGERIA 18 2.1 INTRODUCTION – – – – – – 18 2.2 HISTORY OF CORPORATE TAX LAW IN NIGERIA – – 21 2.2.1 THE PERIOD OF TAX CONSCIOUSNESS – – – – 19 2.2.2 THE PERIOD OF FISCAL MEASURE – – – – – 20 2.2.3 THE PERIOD OF FISCAL CENSURE – – – – – 22 2.2.5 THE PERIOD OF TAX AS INSTRUMENT OF SOCIAL REFORM – 24 2.3 THE CURRENT APPLICABLE LAWS TO CORPORATE TAXATION IN NIGERIA – – – – – – – – – 27 2.4 NATIONAL TAX POLICY AND CORPORATE TAXATION IN NIGERIA 27 2.4.1 MEANING OF NATIONAL TAX POLICY – – – – 29

Chapter THREE

THE BASIC CONCEPTS OF CORPORATE TAX LAWS AND TAXING JURISDICTIONS IN NIGERIA – – – – – – 31 3.1 INTRODUCTION – – – – – – – 31 3.2 THE BASIC CONCEPT AND RATIONAL FOR CORPORATION TAX – 31 3.2.1 INTRODUCTION 3.3 RATIONALE FOR CORPORATION TAX – – – – 33 3.4 DEFINING A COMPANY FOR TAX PURPOSE – – – – 34 3.5 CATEGORIES OF COMPANIES – – – – – – 37 3.6 DISTINGUISHING FEATURES OF CORPORATE TAXATION IN NIGERIA 41 3.7 TAX ON PROFITS OR TURNOVER OF COMPANIES – – – 34 3.8 EXERCISE OF TAXING JURISDICTION – – – – 34 3.8.1 STATUS JURISDICTION – – – – – – – 44 3.8.2. BUSINESS JURISDICTION – – – – – – 45

Chapter FOUR

CHARGEABLE INCOMES OF COMPANIES – – – – 51 4.1 INTRODUCTION – – – – – – – – 51 4.1.0 LAW AND REVENUE PRACTICE – – – – – – 52 4.1.1 RULE OF CONVENIENCE – – – – – – – 54 4.1.2 RULE OF CONCESSION – – – – – – – 55 4.2 MEANING OF INCOME – – – – – – – 55 4.2.1 RECURRENT QUALITY TEST – – – – – – 56 4.2.2 ORDINARY COURSE OF BUSINESS TEST – – – – 57 4.2.3 DESIGNATED SOURCE TEST – – – – – – 59 4.2.4 PRACTICAL APPROACH – – – – – – – 60 4.3 IMPOSITION OF TAX – – – – – – – 61 4.3.1 RENT AND PREMIUM – – – – – – – 64 4.3.2 DIVIDEND AND ANNUITY – – – – – – 65 4.3.3 SECURITY – – – – – – – – – 67 4.4 ASSESSMENT – – – – – – – – 69

ADDITIONAL ASSESSMENT
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CURRENCY OF ASSESSMENT
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4.5 RATES OF TAX AND LEGISLATIVE EQUIVALENCY DOCTRINE – 75

Chapter FIVE

MODALITIES FOR THE TAXATION OF CORPORATE BODIES IN NIGERIA 5. 1 INTRODUCTION – – – – – – – – 77 5. 2 MODALITIES – – – – – – – – – – 77 5.3 SOURCE OF ACCRUAL BASIS AND BASIS OF LIA BILITY TO NIGERIAN TAXATION – – – – – 78 5.4 TYPES OF INCOME ASSESSABLE TO TAX – – – 79 5.4.1 TRADE PROFITS – – – – – – – – 79 5.4.2 INVESTMENT INCOME – – – – – – – 80 5.4.3 INTEREST – – – – – – – – – 80 5.4.4 DEDUCTION OF TAX FROM INTEREST AND RENTS – – 81 5.4.5 ALLOWANCES, DUE AND FEES – – – – – – 82 5.5 INCOME EXEMPTED FROM TAXATION – – – – 82 5.6 CONDITIONS TO QUALIFY FOR PIONEER STATUS – – – 84 5.6.1 PIONEER CERTIFICATE – – – – – – 85 5.6.2 OPERATIONS OF PIONEER COMPANIES – – – 85 5.6.3 COMMENCEMENT OF BUSINESS OR TRADE BY PIONEER COMPANIES – – – – – – 85 5.6.4 POWERS OF F.B.I.R. IN RESPECT OF PIONEER COMPANIES – – 85 5.6.5 RESTRICTIONS OF PIONEER COMPANY – – – 86 5.7 COMPUTATION OF TOTAL PROFITS OF A COMPANY – – – 86 5.7.1 COMMENCEMENT OF A TRADE OR BUSINESS – – – 87 5.7.2 CESSATION/TERMINATION OF TRADE OR BUSINESS – – 87 5.7.3 PAYMENT RECEIVED AFTER THE TERMINATION OF BUSINESS OR TRADE- – – – – – – 88 5.7.4 TRANSFER OR SALE OF BUSINESS OR TRADE – – – – 88 5.7.5 TAKEOVER, MERGER, TRANSFER OR RESTRUCTURING OF BUSINESS – – – – – – – – – 89 5.7.6 THE BASIC RULES FOR CALCULATING A COMPANY’S PROFITS – – – – – – – – – 89 5.7.7 WHERE THERE IS NO ASSESSABLE PROFITS – – – 89 5.7.8 DEDUCTIONS ALLOWED IN COMPUTING PROFITS OF A COMPANY – – – – – – – – 90 5.7.9 DISALLOWABLE DEDUCTION FROM PROFIT – – – – 91 5.8 OTHER CATEGORIES OF DEDUCTIONS ALLOWED FROM PROFITS – – – – – – – – 92 5.9 LOSSES DEDUCTIBLE FROM INCOME FOR TAX PURPOSES – – 92 5.10 CAPITAL ALLOWANCES AS DEDUCTIBLE FROM INCOME FOR TAX PURPOSES – – – – – – 93 5.11 TAXATION OF DORMANT COMPANIES – – – – – 95 5.12 TAXATION OF DIVIDENDS – – – – – – 95 CHAPTER SIX: SUMMARY AND CONCLUSIONS 6.1 SUMMARY – – – – – – – – 104 6.2 FINDINGS – – – – – – – – – 106 6.3 RECOMMENDATIONS – – – – – – – 108 BIBLIOGRAPHY – – – – – – – – 116