Question Tag: FIRS

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ATAX – May 2017 – L3 – Q5 – Transfer Pricing

Explain the significance of transfer pricing, its regulation, and methods.

The dwindling oil revenue in recent times has constrained the earning capacity of the Nigerian government. This situation accelerated the slide in the nation’s economy into recession in 2016. There has been a lot of arguments as to which regime’s actions or inactions brought about this economic malaise. Some experts argue that Nigeria has good tax laws, but successive governments displayed a lack of political will to implement them. They posit that the lack of implementation has caused the nation’s Internally Generated Revenue (IGR) to nosedive.

As part of various recommendations by these experts, coupled with the compelling need to shore up the Internally Generated Revenue, the Federal Inland Revenue Service (FIRS) has created the Transfer Pricing Division located in the FIRS Building at Ikoyi, Lagos. To give teeth to its mandate, the Division has been writing multinationals and groups of companies to file returns with it, in respect of their transfer pricing activities.

MGBORIE GROUP LIMITED recently received one of such letters from the FIRS, which startled the Chairman/Chief Executive who is already sensing rough times with the FIRS.

As the company’s tax consultant, the letter was forwarded to you for further explanations.

You are required to state:
a. The significance of Transfer Pricing. (2 Marks)
b. TWO objectives of the Income Tax (Transfer Pricing) Regulation Act of 2012. (2 Marks)
c. Contents of the Transfer Pricing Disclosure and Submission Forms to the FIRS. (5 Marks)
d. THREE Transfer Pricing Methods. (6 Marks)

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ATAX – May 2019 – L3 – Q2 – Tax Administration and Dispute Resolution

Discuss the distinction between tax evasion and avoidance, provide solutions, and evaluate Nigeria’s anti-avoidance legislation.

You have been approached by the managing director of a manufacturing company, Ojieaga Integrated Limited, for professional advice on tax evasion and tax avoidance and their challenges to an equitable tax system in Nigeria. Your report is expected to guide the operation of the business, having been subjected in the last three years to various forms of fines and penalties by the Federal Inland Revenue Service on confirmed cases of sharp business practices with their attendant loss of tax revenue to the government.

Required:
Having accepted the terms of engagement, you are to write a report to management for consideration at its next meeting, dealing with the following areas of concern:

a. Distinction between tax evasion and tax avoidance, highlighting THREE examples of each case. (6 Marks)
b. Seven solutions to the problem of tax evasion and tax avoidance. (7 Marks)
c. Comment on anti-avoidance legislations in Nigeria. (7 Marks)

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AT – Nov 2017 – L3 – Q7 – Tax Implications of Mergers and Acquisitions

Advise on tax implications for Aba Foods merger/acquisition options with Ifedi Foods.

The prevailing economic condition has led to the business cessation of many SMEs. Aba Foods Limited, a well-known food and beverage company in Abia State, faced difficulties in securing long-term loans, preventing the replacement of its outdated equipment and leading to losses. To ensure continuity, the company considered mergers or acquisitions and entered discussions with Chief Egodi of Ifedi Group. Chief Egodi, concerned about the tax implications of potential arrangements, sought advice from your firm, Aliyara & Co., Chartered Accountants.

Required:
Provide a presentation in the form of advice:

(a) Explain the tax implications of Aba Foods Limited merging with Ifedi Foods and Beverage Limited, with Ifedi inheriting all assets and liabilities. (5 Marks)
(b) Explain the tax implications if Ifedi Foods and Beverage Limited is reconstituted to take over Aba Foods’ assets and liabilities. (5 Marks)
(c) Explain the tax implications if Ifedi Foods and Aba Foods enter a Joint Venture or Partnership Agreement. (5 Marks)

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AT – Nov 2017 – L3 – Q5 – Tax Administration and Dispute Resolution

Outline objection and appeal procedures for FIRS additional assessment.

Papa Ejima Limited, a manufacturing company, filed tax returns for the 2014 Assessment Year. The Federal Inland Revenue Service (FIRS) issued additional assessments totaling N360,000 for Value Added Tax (VAT) and N3,050,000 for Withholding Tax (WHT). The Managing Director disputes this assessment, asserting the accuracy of the company’s tax filings.

The records of the company for the Accounting Year ended December 31, 2013 showed:

Description Amount (N)
Revenue 187,500,000
Cost of sales (102,500,000)
Gross Profit 85,000,000
Other income 31,250,000
Operating expenses (57,250,000)
Interest and similar charges (3,200,000)
Profit before tax 55,800,000
Taxation (6,250,000)
Profit after tax 49,550,000
Dividend (38,500,000)
Retained profit for the year 11,050,000

Other relevant information includes:

  1. Revenue:
    • Export sales: N58,500,000
    • Local sales: N129,000,000
  2. Cost of sales:
    • Opening inventory (VAT inclusive): N22,800,000
    • Closing stock (VAT inclusive): N37,150,000
    • Purchase of raw material: N90,600,000
    • Freight charges: N18,700,000
    • Other direct materials: N27,550,000
  3. Other income:
    • Foreign exchange gain: N4,800,000
    • Profit on sale of Non-current assets (sales proceeds is N21.5m): N8,850,000
    • Management fees from subsidiary companies: N17,600,000
  4. Operating expenses:
    • Office rent: N18,000,000
    • Audit fees: N4,000,000
    • Consultancy fees to ZXY Ltd: N11,000,000
    • Directors’ fees: N7,500,000
    • Other expenses: N16,750,000
  5. Additional details:
    • The company purchased Non-Current Assets (VAT inclusive): N84,000,000
    • VAT remitted to FIRS during the year: N1,976,235
    • WHT remitted to FIRS during the year: N6,650,000

Required:
As the tax consultant for the company, prepare a memo to advise the Managing Director on the appropriate objection and appeal procedures available to the company under the tax regulations.

(Total 15 Marks)

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TAX – Nov 2020 – L1 – SA – Q5 – Tax Administration and Enforcement

Identify the correct name for the management board of the Federal Inland Revenue Service.

The management board of the Federal Inland Revenue Service is known as:
A. Federal Inland Revenue Service Board
B. Federal Internal Revenue Service Board
C. Board of Federal Inland Revenue Service
D. Board of Federal Revenue Service
E. Federal Board of Inland Revenue Service

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TAX – Nov 2020 – L1 – SA – Q2 – Tax Administration and Enforcement

Identify the member who is not part of the FIRSB Technical Committee.

The Technical Committee of the Federal Inland Revenue Service Board (FIRSB) is composed of the following members, EXCEPT:
A. The Executive Chairman of Federal Inland Revenue Service (FIRS)
B. All directors and heads of department of FIRS
C. The Legal Adviser to FIRS
D. Secretary to FIRSB
E. Director, Federal Ministry of Finance

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TAX – May 2021 – L1 – SA – Q11 – Tax Administration and Enforcement

Objective question about the penalty for failure to notify FIRS of change of address within a specified time frame.

In respect of VAT, a person who fails to notify the FIRS of any change of address within one month of such change is liable to pay a penalty of:
A. N25,000
B. N20,000
C. N15,000
D. N10,000
E. N5,000

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TAX – May 2021 – L1 – SA – Q9 – Tax Administration and Enforcement

Multiple-choice question regarding the time frame for refund of excess withholding tax deducted.

In line with the Federal Inland Revenue Service (Establishment) Act, 2007, any excess withholding tax deducted should be refunded within……………….of the decision of the Service of refund.
A. 120 days
B. 90 days
C. 60 days
D. 40 days
E. 30 days

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TAX – May 2021 – L1 – SA – Q7 – Tax Administration and Enforcement

Multiple-choice question regarding the deadline for companies to file tax returns with the Federal Inland Revenue Service (FIRS).

Within how many months after the end of an accounting year should an existing company file its tax returns with the Federal Inland Revenue Service?
A. 12 months
B. 10 months
C. 8 months
D. 6 months
E. 4 months

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ATAX – May 2017 – L3 – Q5 – Transfer Pricing

Explain the significance of transfer pricing, its regulation, and methods.

The dwindling oil revenue in recent times has constrained the earning capacity of the Nigerian government. This situation accelerated the slide in the nation’s economy into recession in 2016. There has been a lot of arguments as to which regime’s actions or inactions brought about this economic malaise. Some experts argue that Nigeria has good tax laws, but successive governments displayed a lack of political will to implement them. They posit that the lack of implementation has caused the nation’s Internally Generated Revenue (IGR) to nosedive.

As part of various recommendations by these experts, coupled with the compelling need to shore up the Internally Generated Revenue, the Federal Inland Revenue Service (FIRS) has created the Transfer Pricing Division located in the FIRS Building at Ikoyi, Lagos. To give teeth to its mandate, the Division has been writing multinationals and groups of companies to file returns with it, in respect of their transfer pricing activities.

MGBORIE GROUP LIMITED recently received one of such letters from the FIRS, which startled the Chairman/Chief Executive who is already sensing rough times with the FIRS.

As the company’s tax consultant, the letter was forwarded to you for further explanations.

You are required to state:
a. The significance of Transfer Pricing. (2 Marks)
b. TWO objectives of the Income Tax (Transfer Pricing) Regulation Act of 2012. (2 Marks)
c. Contents of the Transfer Pricing Disclosure and Submission Forms to the FIRS. (5 Marks)
d. THREE Transfer Pricing Methods. (6 Marks)

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ATAX – May 2019 – L3 – Q2 – Tax Administration and Dispute Resolution

Discuss the distinction between tax evasion and avoidance, provide solutions, and evaluate Nigeria’s anti-avoidance legislation.

You have been approached by the managing director of a manufacturing company, Ojieaga Integrated Limited, for professional advice on tax evasion and tax avoidance and their challenges to an equitable tax system in Nigeria. Your report is expected to guide the operation of the business, having been subjected in the last three years to various forms of fines and penalties by the Federal Inland Revenue Service on confirmed cases of sharp business practices with their attendant loss of tax revenue to the government.

Required:
Having accepted the terms of engagement, you are to write a report to management for consideration at its next meeting, dealing with the following areas of concern:

a. Distinction between tax evasion and tax avoidance, highlighting THREE examples of each case. (6 Marks)
b. Seven solutions to the problem of tax evasion and tax avoidance. (7 Marks)
c. Comment on anti-avoidance legislations in Nigeria. (7 Marks)

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AT – Nov 2017 – L3 – Q7 – Tax Implications of Mergers and Acquisitions

Advise on tax implications for Aba Foods merger/acquisition options with Ifedi Foods.

The prevailing economic condition has led to the business cessation of many SMEs. Aba Foods Limited, a well-known food and beverage company in Abia State, faced difficulties in securing long-term loans, preventing the replacement of its outdated equipment and leading to losses. To ensure continuity, the company considered mergers or acquisitions and entered discussions with Chief Egodi of Ifedi Group. Chief Egodi, concerned about the tax implications of potential arrangements, sought advice from your firm, Aliyara & Co., Chartered Accountants.

Required:
Provide a presentation in the form of advice:

(a) Explain the tax implications of Aba Foods Limited merging with Ifedi Foods and Beverage Limited, with Ifedi inheriting all assets and liabilities. (5 Marks)
(b) Explain the tax implications if Ifedi Foods and Beverage Limited is reconstituted to take over Aba Foods’ assets and liabilities. (5 Marks)
(c) Explain the tax implications if Ifedi Foods and Aba Foods enter a Joint Venture or Partnership Agreement. (5 Marks)

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AT – Nov 2017 – L3 – Q5 – Tax Administration and Dispute Resolution

Outline objection and appeal procedures for FIRS additional assessment.

Papa Ejima Limited, a manufacturing company, filed tax returns for the 2014 Assessment Year. The Federal Inland Revenue Service (FIRS) issued additional assessments totaling N360,000 for Value Added Tax (VAT) and N3,050,000 for Withholding Tax (WHT). The Managing Director disputes this assessment, asserting the accuracy of the company’s tax filings.

The records of the company for the Accounting Year ended December 31, 2013 showed:

Description Amount (N)
Revenue 187,500,000
Cost of sales (102,500,000)
Gross Profit 85,000,000
Other income 31,250,000
Operating expenses (57,250,000)
Interest and similar charges (3,200,000)
Profit before tax 55,800,000
Taxation (6,250,000)
Profit after tax 49,550,000
Dividend (38,500,000)
Retained profit for the year 11,050,000

Other relevant information includes:

  1. Revenue:
    • Export sales: N58,500,000
    • Local sales: N129,000,000
  2. Cost of sales:
    • Opening inventory (VAT inclusive): N22,800,000
    • Closing stock (VAT inclusive): N37,150,000
    • Purchase of raw material: N90,600,000
    • Freight charges: N18,700,000
    • Other direct materials: N27,550,000
  3. Other income:
    • Foreign exchange gain: N4,800,000
    • Profit on sale of Non-current assets (sales proceeds is N21.5m): N8,850,000
    • Management fees from subsidiary companies: N17,600,000
  4. Operating expenses:
    • Office rent: N18,000,000
    • Audit fees: N4,000,000
    • Consultancy fees to ZXY Ltd: N11,000,000
    • Directors’ fees: N7,500,000
    • Other expenses: N16,750,000
  5. Additional details:
    • The company purchased Non-Current Assets (VAT inclusive): N84,000,000
    • VAT remitted to FIRS during the year: N1,976,235
    • WHT remitted to FIRS during the year: N6,650,000

Required:
As the tax consultant for the company, prepare a memo to advise the Managing Director on the appropriate objection and appeal procedures available to the company under the tax regulations.

(Total 15 Marks)

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TAX – Nov 2020 – L1 – SA – Q5 – Tax Administration and Enforcement

Identify the correct name for the management board of the Federal Inland Revenue Service.

The management board of the Federal Inland Revenue Service is known as:
A. Federal Inland Revenue Service Board
B. Federal Internal Revenue Service Board
C. Board of Federal Inland Revenue Service
D. Board of Federal Revenue Service
E. Federal Board of Inland Revenue Service

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TAX – Nov 2020 – L1 – SA – Q2 – Tax Administration and Enforcement

Identify the member who is not part of the FIRSB Technical Committee.

The Technical Committee of the Federal Inland Revenue Service Board (FIRSB) is composed of the following members, EXCEPT:
A. The Executive Chairman of Federal Inland Revenue Service (FIRS)
B. All directors and heads of department of FIRS
C. The Legal Adviser to FIRS
D. Secretary to FIRSB
E. Director, Federal Ministry of Finance

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TAX – May 2021 – L1 – SA – Q11 – Tax Administration and Enforcement

Objective question about the penalty for failure to notify FIRS of change of address within a specified time frame.

In respect of VAT, a person who fails to notify the FIRS of any change of address within one month of such change is liable to pay a penalty of:
A. N25,000
B. N20,000
C. N15,000
D. N10,000
E. N5,000

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TAX – May 2021 – L1 – SA – Q9 – Tax Administration and Enforcement

Multiple-choice question regarding the time frame for refund of excess withholding tax deducted.

In line with the Federal Inland Revenue Service (Establishment) Act, 2007, any excess withholding tax deducted should be refunded within……………….of the decision of the Service of refund.
A. 120 days
B. 90 days
C. 60 days
D. 40 days
E. 30 days

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TAX – May 2021 – L1 – SA – Q7 – Tax Administration and Enforcement

Multiple-choice question regarding the deadline for companies to file tax returns with the Federal Inland Revenue Service (FIRS).

Within how many months after the end of an accounting year should an existing company file its tax returns with the Federal Inland Revenue Service?
A. 12 months
B. 10 months
C. 8 months
D. 6 months
E. 4 months

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