In Star Deep Water Petroleum Ltd v. Lagos State Internal Revenue Service, the Tax Appeal Tribunal (TAT) Lagos division held that an assessment that is not compliant with the law cannot become final and conclusive.

The TAT also held that Regulation 2(2) of the PAYE Regulations which requires a 'manager' to act in place of an employer by furnishing the relevant tax authorities with employees' emoluments, deducting and remitting tax do not apply where the manager is not the one paying the employees' emoluments.

Read our alert for further insights Download PwC Tax Alert_Assessments not in line with the law cannot be final & conclusive

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