By Zhihwi Dauda Esq and Somtochukwu Allwell Esq

1. INTRODUCTION

The taxation of corporate income in Nigeria traces its origins to the colonial period, when the Companies Income Tax Ordinance, No. 6 of 1939, first imposed a charge on the profits of incorporated trading concerns operating within Nigerian territory.[1] Following the attainment of fiscal autonomy in the post-independence era, this Ordinance evolved through successive statutory instruments, culminating in the Companies Income Tax Act, Cap. C21, Laws of the Federation of Nigeria, 2004 (CITA), which governed the assessment and collection of companies income tax in Nigeria for over six decades.[2] CITA, like its forebears, was animated by an enduring fiscal philosophy: that companies deriving profit from economic activity within Nigeria owe a civic duty to contribute to the public purse for the maintenance of governance and infrastructure.[3] This philosophy found renewed expression on 1st January, 2026, when CITA, along with several other extant revenue statutes, was repealed and consolidated into the Nigeria Tax Act, 2025 (“NTA” or “the Act”), Nigeria’s first unified fiscal code.[4] From its earliest iterations, however, the law has always carved out a narrow class of exemption for entities whose object is not the accumulation of private wealth but the advancement of religion, charity, or education for the benefit of the public at large. It is this exemption, and the controversy it has periodically engendered, that forms the subject of this appraisal. The policy rationale underlying the exemption is neither arbitrary nor sentimental; it rests on the principle that organisations which relieve the State of obligations it would otherwise bear, the education of the young, the relief of poverty, the propagation of faith and morals, perform a quasi-governmental function and ought not to be taxed on the very resources they apply toward that function.[5] To extend the exemption beyond this purpose, however, to commercial ventures merely cloaked in benevolent language, would not only deplete the revenue available for redistribution to the generality of citizens, but would also confer an unfair competitive advantage upon businesses that masquerade as charities while their promoters quietly appropriate the profit.[6] It is precisely this tension, between genuine public-benefit activity and disguised private enterprise, that lay at the heart of the decade-long litigation between Best Children International School Limited and the Federal Inland Revenue Service, culminating in the Supreme Court’s judgment of 19th June, 2026.

Prior to its repeal, the exemption was codified in section 23(1)(c) of CITA, which provided that there shall be exempt from tax “the profits of any company engaged in ecclesiastical, charitable or education activities of a public character in so far as such profits are not derived from a trade or business carried on by such company.”[7] Judicial and administrative gloss distilled three cumulative pre-conditions from this provision: first, that the profits be derived from ecclesiastical, charitable, or educational activity; second, that the company possess the attribute of “public character”; and third, that the profits sought to be exempted must not themselves be derived from a trade or business carried on by the company.[8] Because CITA itself did not define “public character,” the Federal Inland Revenue Service, acting pursuant to section 61 of the Federal Inland Revenue Service (Establishment) Act, 2007, issued the Requirements for Funds, Bodies or Institutions under the Fifth Schedule to the Companies Income Tax Act Regulations, 2011, which defined the phrase as a body whose activities benefit Nigerians generally and whose profits are not available for distribution to its promoters.[9] It was against this statutory and regulatory backdrop that Best Children International School Limited, a company duly incorporated and limited by shares under the Companies and Allied Matters Act, and operating a fee-paying private school in Abuja, resisted companies income tax assessments raised against it by the Federal Inland Revenue Service, on the footing that its profits, being derived from educational activity, were exempt under section 23(1)(c) of CITA.[10] The dispute, which commenced before the Federal High Court in suits numbered FHC/ABJ/CS/867/2014 and FHC/ABJ/CS/1004/2016, traversed the Court of Appeal, which on 11th December, 2018 unanimously affirmed the trial Court’s finding that the Appellant lacked the requisite public character before culminating, after a decade of litigation, in the judgment of the Supreme Court delivered on 19th June, 2026 in Appeal No. SC/38/2019.[11]

This article seeks to critically appraise the Supreme Court judgment in SC.38/2019 – Best International School Ltd v. FIRS, and to assess its implications for the tax exemption of educational, religious and charitable organizations under Section 162(1)(a)(iii) of the Nigeria Tax Act, 2025. By tracing the historical background of the exemption under the repealed CITA, analyzing the facts, arguments and judicial reasoning in the decade-long litigation, and relating the Court’s principles to the new statutory definition of “public character” under the NTA 2025, the article aims to clarify the scope of the exemption, highlight implementation challenges, and proffer recommendations to ensure effective and consistent application of the law going forward.

2. BRIEF OF THE FACTS OF THE CASE

The Appellant, Best Children International School Limited, is a company incorporated and registered as a company limited by shares under the Companies and Allied Matters Act, and carries on the business of providing private, fee-paying primary and secondary education in Abuja.12 Following its assessment to companies income tax by the Federal Inland Revenue Service (the Respondent) in respect of profits derived from the operation of the school, the Appellant objected to the assessments and thereafter instituted proceedings before the Federal High Court, contending that, as a body engaged in educational activity, its profits were exempt from companies income tax by virtue of section 23(1)(c) of CITA, and sought, inter alia, an order prohibiting the Respondent from imposing or enforcing companies income tax against it.[12] Honourable Justice

Ademola of the Federal High Court, Abuja Division, dismissed the Appellant’s claim and held that the reliefs sought could not be sustained. Dissatisfied, the Appellant appealed to the Court of Appeal, Abuja Division, which, in a judgment delivered on 11th December, 2018, unanimously dismissed the appeal and affirmed the finding that the Appellant lacked the public character required to benefit from the exemption.[13] The Appellant thereafter approached the Supreme Court by way of further appeals, raising substantially the same grounds in respect of both suits, registered respectively as Appeal Nos. SC/38/2019 and SC/39/2019.

2.1The Argument of the Appellant (Best International School Ltd) before the Supreme Court

Although the Appellant’s brief of argument is not, of itself, reproduced in this appraisal, its essential contentions may be gleaned from the issues which the Respondent was at pains to rebut.[14] The Appellant’s case proceeded substantially on three planks. First, the Appellant contended that, being engaged in educational activity, it fell squarely within the class of entities contemplated by section 23(1)(c) of CITA, and that the absence of a statutory definition of “public character” in CITA itself meant that the term ought to be construed liberally in its favour. Second, the Appellant argued that the mere fact that its school was open to any member of the public able and willing to enroll was sufficient to clothe it with the requisite public character, notwithstanding that it operated as a company limited by shares whose profits accrued to its shareholders. Third, the Appellant complained that the Court of Appeal had breached its right to fair hearing by failing to consider certain issues it claimed were material to the determination of the appeal.

2.2 The Argument of the Respondent (FIRS-NRS) before the Supreme Court

The Respondent’s briefs of argument, filed in respect of both appeals, advanced a unified and consistent position. It was submitted that section 23(1)(c) of CITA imposes three cumulative pre-conditions which must co-exist before any company may claim the exemption, namely, that the profits be derived from ecclesiastical, charitable, or educational activity of a public character, and that such profits must not themselves be derived from a trade or business carried on by the company.[15] Drawing on the ejusdem generis rule of interpretation, as restated by the Supreme Court in Buhari V. Yusuf[16], the Respondent submitted that the general words “of a public character” must take colour from the specific words “ecclesiastical” and “charitable” which precede them, such that only bodies whose substance, and not merely whose outward appearance, is non-commercial in character can qualify. The Respondent further relied on the Fifth Schedule Regulations of 2011, which define “public character” as activity benefiting Nigerians generally, the profits of which are not available for distribution to promoters, and submitted that this definition was consistent with comparable provisions in other jurisdictions, including section 30(1) of the Income Tax Act No. 58 of 1962 of the Republic of South Africa.[17] It was further submitted that, being a company limited by shares incorporated under section 22 of the Companies and Allied

Matters Act, the Appellant’s profits were, in law, distributable to its shareholders, and that the Appellant had neither pleaded nor led evidence at trial to establish that its profits were applied solely toward the promotion of its educational object rather than distributed as business profit, a position consistent with the earlier holding in Trustees of Methodist Church Mission v. Federal Inland Revenue Service[18], where the Federal Revenue Court held that a body otherwise enjoying ecclesiastical exemption nonetheless remained liable to tax on income derived from carrying on the business of dealing in real estate. The Respondent also invoked the House of Lords’ enumeration in Income Tax Special Commissioners v. Pemsel of the heads of charity, relief of poverty, advancement of education, advancement of religion, and other purposes beneficial to the community, to demonstrate that none of these heads contemplates the private enrichment of promoters or shareholders, and urged the Court to construe section 23(1)(c) of CITA, as a provision of a revenue statute, liberally in favour of revenue, in line with the principle established in Phoenix Motors Ltd v. National Provident Fund Management Board.[19] On the question of fair hearing, the Respondent submitted, relying on Odi v. Osafile and Uzudu v. Ebigah, that a court is only bound to determine issues material to the resolution of the case before it, and that the Court of Appeal’s silence on issues subsumed within its central finding could not amount to a breach of fair hearing.[20] The Respondent accordingly urged the Supreme Court to dismiss the appeal and to affirm the concurrent findings of the trial Court and the Court of Appeal that the Appellant, being a profit-making enterprise whose proceeds inure to its shareholders, lacked the public character contemplated by section 23(1)(c) of CITA, and was therefore not exempt from companies income tax.

2.3 The Final Judgment of the Supreme Court

The Supreme Court delivered its judgment in Appeal No. SC/38/2019 on 19th June, 2026, Abraham M.S JSC read the lead judgment in an open court bringing to a close a dispute that had spanned approximately a decade from the institution of the earlier suit.[21] Both author where present at the court on the said date. The certified true copy of the Supreme Court’s judgment, including the precise holding, and the specific paragraphs of the ratio decidendi, had not been made available yet as at the date of this appraisal, and readers are respectfully urged to verify the discussion in this section against that certified record before relying on it. What may be stated with confidence, given the unbroken trajectory of the litigation, in which both the trial Court and the Court of Appeal concurrently found that the Appellant lacked the public character necessary to ground the exemption, and in which the Respondent’s position remained materially unchanged across both appeals before the apex Court, is that the judgment falls to be read as either affirming or substantially adopting the reasoning canvassed above: namely, that a company limited by shares, whose profits are in law distributable to its shareholders, cannot, merely by reason of operating a school open to the paying public, clothe itself with the public character necessary to escape companies income tax liability under section 23(1)(c) of CITA.[22]  The Supreme court dismissed the appeal for lacking in substance and make no order as to cost. This appraisal proceeds on that basis.

  1. Treatment of Tax Exemption of Income From Educational, Religious and Charitable Organizations under Section 162(1)(a)(iii) of the Nigeria Tax Act 2024

The Nigeria Tax Act, 2025, which came into force on 1st January, 2026, repeals CITA in its entirety but carries forward, in modernized form, the exemption upon which the Best Children litigation turned.24 Section 162(1)(a)(iii) of the NTA exempts from tax “the profits accruing to, or gains from disposal of assets of any person… engaged in educational, religious or charitable activities of a public character where the profits or gains are not derived from a trade or business carried on by such person.”[23] The structure of the provision is, in all material respects, identical to that of its predecessor: a qualifying activity, the attribute of public character, and the exclusion of profits derived from trade or business. What has changed, and changed decisively, is that the NTA no longer leaves “public character” to be defined by subsidiary legislation alone. Section 201 of the NTA Act 2025, its general interpretation section, now defines

“public character,” with respect to any organisation or institution, to mean an organisation or institution that is registered in accordance with relevant law in Nigeria, and that does not distribute or share its profit in any manner to members or promoters.[24] This statutory definition is, in substance, the very test which the Federal Inland Revenue Service had hitherto sought to enforce by way of the 2011 Fifth Schedule Regulations, and which the Appellant in Best Children had argued was a mere administrative gloss without the force of the parent Act. By elevating that definition into the body of the principal legislation itself, the NTA forecloses the very argument that animated a decade of litigation: a taxpayer can no longer contend that the “nodistribution” requirement is merely regulatory and therefore of doubtful application. The exemption is reinforced elsewhere in the Act. Section 55(1)(a) of the NTA 2026 exempts from chargeable gains tax property held in trust for a religious or charitable institution of a public character, on the like proviso that the gain is not derived from the disposal of an asset connected with any trade or business carried on by the institution, and that the gain is applied solely for the institution’s purpose.[25] Read together, sections 55, 162, and 201 of the NTA constitute a coherent statutory scheme that preserves the policy underlying the old section 23(1)(c) of CITA while closing the interpretive gap that the Appellant in Best Children sought to exploit.

3.1 Cases Law Jurisprudent On The Subject Matter:

The jurisprudence developed under the repealed CITA remains, in this my respectful view, of continuing relevance and persuasive authority in the construction of section 162(1)(a)(iii) of the NTA, given the structural identity between the two provisions. Of particular continuing relevance are: Trustees of Methodist Church Mission v. Federal Inland Revenue Service[26], on the principle that engaging in a trade or business removes profits from the scope of the exemption regardless of the status of the owner; Income Tax Special Commissioners v. Pemsel[27], on the four heads of charitable purpose; Buhari v. Yusuf[28], on the application of the ejusdem generis rule to general words following particular words in a statutory provision; Phoenix Motors Ltd v.

National Provident Fund Management Board[29] and Federal Board of Inland Revenue v.

I.D.S. Ltd32, on the principle that revenue statutes are to be construed liberally in favour of revenue absent a clear provision to the contrary; Federal Board of Inland Revenue v. Nigerian National Supply Co. Ltd[30], Cocoa Industries Ltd v. Federal Board of Inland Revenue[31], Shell Petroleum Development Company of Nigeria Ltd v. Federal Board of Inland Revenue[32][33], Lagos State Board of Internal Revenue v. Eko Hotels Ltd[34], and Federal Inland Revenue Service v. NNPC37, on the settled principle that exemptions from tax must be expressly and clearly conferred by statute and will not be presumed or extended by implication; and Mobil Oil (Nigeria) Ltd v. Federal Board of Inland Revenue[35], on the purposive approach to be adopted where a literal construction would defeat the evident object of a taxing provision. It is submitted that these authorities will continue to guide the Nigeria Revenue Service and the Tax Appeal Tribunal in the application of section 162(1)(a)(iii) of the NTA, save to the extent that the statutory definition of

“public character” now contained in section 201 of the Act renders certain of the older interpretive debates, particularly as to the legal force of the 2011 Regulations moot.

4. CHALLENGES AFFECTING THE EFFECTIVE IMPLEMENTATION OF THE INCOME TAX EXEMPTION OF CHARITABLE ORGANISATIONS UNDER THE NTA 2025

Notwithstanding the welcome clarity introduced by section 201 of the NTA, a number of practical and administrative challenges are likely to attend the effective implementation of the exemption regime going forward.

  1. The Nigeria Revenue Service, as successor to the Federal Inland Revenue Service, will require updated subsidiary regulations specifically issued under the NTA to operationalize section 162(1)(a)(iii) NTA; the 2011 Fifth Schedule Regulations were made pursuant to the now-repealed Federal Inland Revenue Service (Establishment) Act and CITA, and their continued application, absence fresh regulations made pursuant to NTA 2025, may itself become a fertile source of further litigation. Though the saving provision of Section 41(f) of Nigeria Revenue Service Establishment Act 2025[36]
  2. There remains a structural verification challenge: the Service has historically to some extend weak administrative capacity in conducting periodic compliance audits of bodies claiming public-character status, with the result that an entity may continue to self-assess as exempt for years before any assessment is raised, precisely as occurred in Best Children.[37]
  3. The statutory test continues to draw a sharp binary between companies limited by guarantee under section 26 of the Companies and Allied Matters Act and companies limited by shares, yet a growing number of genuine social enterprises, particularly in education and healthcare, are structured as companies limited by shares for entirely legitimate commercial-governance reasons while still directing the bulk of their surplus toward public-benefit ends; the current framework offers such hybrid entities no intermediate recognition.
  4. The absence of a public online searchable register of organisations certified as possessing public character continues to create uncertainty for both taxpayers and tax administrators as to which entities are, at any given time, validly exempt.
  5. The protracted nature of the Best Children litigation, a decade from the institution of suit to final determination by the apex Court, illustrates a broader institutional challenge of delay in the resolution of tax disputes, which imposes significant compliance and litigation costs on both the taxpayer and the Service, and undermines the certainty that a well-functioning tax system requires.

5. RECOMMENDATIONS

Arising from the foregoing, the following recommendations are respectfully proffered.

  1. The Nigeria Revenue Service should, as a matter of priority, issue updated regulations under the Nigeria Revenue Service (Establishment) Act and the NTA, expressly defining the procedure by which an organisation may apply for and be certified as possessing “public character” within the meaning of section 201 of the Act, and expressly saving or re-enacting the substance of the 2011 Fifth Schedule Regulations to avoid an interpretive vacuum.[38]
  2. The Service should establish and maintain a public online searchable register of organisations certified as possessing public character, to be updated periodically, so as to give both the organisations themselves and third parties, including donors and the Service’s own assessment officers, certainty as to exempt status at any given time.
  3. The Service should institute a dedicated compliance unit charged with the periodic audit of organisations claiming the exemption, to verify on a continuing basis that profits are not, in fact, being distributed to promoters or members in contravention of section 201 of the Act.
  4. Consideration should be given to a statutory or regulatory framework recognizing an intermediate category of “public-benefit company,” permitting companies limited by shares that voluntarily commit a defined proportion of surplus to their stated publicbenefit object, on terms analogous to, but short of, full conversion to a company limited by guarantee to access a measure of exemption proportionate to that commitment, rather than the present all-or-nothing approach.
  5. The Service, in conjunction with the Tax Appeal Tribunal and the Federal High Court (Revenue Division), should explore streamlined procedural mechanisms, including mandatory pre-action mediation in tax-exemption disputes, to avoid a recurrence of the decade-long delay that characterized the Best Children litigation.
  6. Continuous capacity-building should be undertaken for officers of the Litigation and Prosecution Department of the Service, to ensure that assessments and the conduct of disputes in this specialised area keep pace with the statutory and jurisprudential developments introduced by the NTA.

6. CONCLUSION

The Supreme Court’s judgment of 19th June, 2026 in Best Children International School Ltd v. Federal Inland Revenue Service brings to a definitive close a decade of litigation over the scope of the exemption for charitable, religious and educational organisations under section 23(1)(c) of the now-repealed Companies Income Tax Act. The consistent thread running through the trial Court, the Court of Appeal, and, it is submitted, the Supreme Court itself, is that the exemption was never intended as a vehicle by which private commercial enterprise could escape the ordinary incidence of companies’ income tax merely by adopting the language of charity or education; it was, and remains, reserved for bodies whose profits genuinely inure to the public rather than to private shareholders or promoters. The Nigeria Tax Act, 2025 has taken the additional and welcome step of codifying that very test, in section 201, as a matter of primary legislation, thereby closing the interpretive gap that the Appellant in Best Children sought, unsuccessfully, to exploit. What remains is the harder task of administrative implementation, the issuance of updated regulations, the building of verification capacity, and the reduction of the kind of protracted delay that allowed a single dispute to occupy the courts for ten years. It is hoped that the recommendations proffered in this appraisal will, in some small measure, contribute to that task.

Zhihwi Dauda Esq. (LL. B, B.L, LL.M, ACE, FCIT, PGDE), E-mail: daudathihwi@gmail.com Phone: 08059538671 And Somtochukwu Allwell Esq (LL.B, B.L, ICMC)

Email: enendusomtochukwu@gmail.com Phone no: 08144634913

[1] Companies Income Tax Ordinance, No. 6 of 1939; see generally the historical account in the Respondent’s Brief of Argument, Appeal No. SC/38/2019, dated 4th March, 2020.

[2] Companies Income Tax Act, Cap. C21, Laws of the Federation of Nigeria, 2004 (“CITA”).

[3] Phoenix Motors Ltd v. National Provident Fund Management Board (1993) 1 NWLR (Pt. 272) 718 at 731, paras. D-F.

[4] Nigeria Tax Act, 2025 (Act No. 7 of 2025), Federal Republic of Nigeria Official Gazette No. 117, Vol. 112, 26th June, 2025; section 2 thereof providing for commencement on 1st January, 2026.

[5] Income Tax Special Commissioners v. Pemsel (1890–1898) 3 TC 53.

[6] Respondent’s Amended Brief of Argument, Appeal No. SC/39/2019, paras. 20–21.

[7] CITA, Cap. C21, LFN 2004, s.23(1)(c).

[8] Respondent’s Brief of Argument, Appeal No. SC/38/2019, para. 10; Respondent’s Amended Brief of Argument, Appeal No. SC/39/2019, para. 7.

[9] Requirements for Funds, Bodies or Institutions under the Fifth Schedule to the Companies Income Tax Act Regulations, 2011, para. 9, made pursuant to section 61 of the Federal Inland Revenue Service (Establishment) Act, 2007.

[10] Suit No. FHC/ABJ/CS/867/2014; Suit No. FHC/ABJ/CS/1004/2016.

[11] Court of Appeal, Abuja Division, Appeal No. CA/A/393/2016, judgment delivered 11th December, 2018. 12Companies and Allied Matters Act, Cap. C20, LFN 2004, s.22.

[12] Respondent’s Brief of Argument, Appeal No. SC/38/2019, paras. 1–2; Respondent’s Amended Brief of Argument, Appeal No. SC/39/2019, paras. 2–3.

[13] Court of Appeal, Abuja Division, judgment delivered 11th December, 2018, as recited in the Respondent’s Amended Brief of Argument, Appeal No. SC/39/2019, para. 3.

[14] The Appellant’s Brief of Argument was not available to this writer; the summary herein is drawn from the issues identified for rebuttal in the Respondent’s two Briefs of Argument.

[15] Respondent’s Amended Brief of Argument, Appeal No. SC/39/2019, paras. 7–8.

[16] Buhari v. Yusuf (2003) 14 NWLR (Pt. 841) 446 at 486–487, per Uwaifo, JSC.

[17] Income Tax Act No. 58 of 1962 (Republic of South Africa), s.30(1).

[18] Trustees of Methodist Church Mission v. Federal Inland Revenue Service (1 FRCR) 74.

[19] Phoenix Motors Ltd v. National Provident Fund Management Board (1993) 1 NWLR (Pt. 272) 718; I.T. Special Commissioners v. Pemsel (1890–1898) 3 TC 53.

[20] Odi v. Osafile (1985) 1 NWLR (Pt. 1) 17; Uzudu v. Ebigah (2009) 15 NWLR (Pt. 1163) 1; Hajiya Iyya Alhassan Duzu & Anor v. Alhaji Jibril Yunusa & Ors (2010) LPELR-8989(CA).

[21] Suit No. FHC/ABJ/CS/1004/2016, instituted 2016; Appeal No. SC/38/2019 decided 19th June, 2026.

[22] This passage represents the writer’s reasoned inference from the consistent findings of the courts below and ought to be verified against the certified true copy of the Supreme Court’s judgment. 24Nigeria Tax Act, 2025, s.2.

[23] Nigeria Tax Act, 2025, s.162(1)(a)(iii).

[24] Nigeria Tax Act, 2025, s.201.

[25] Nigeria Tax Act, 2025, s.55(1)(a).

[26] Trustees of Methodist Church Mission v. Federal Inland Revenue Service (1 FRCR) 74.

[27] Income Tax Special Commissioners v. Pemsel (1890–1898) 3 TC 53.

[28] Buhari v. Yusuf (2003) 14 NWLR (Pt. 841) 446.

[29] Phoenix Motors Ltd v. National Provident Fund Management Board (1993) 1 NWLR (Pt. 272) 718;  32 Federal Board of Inland Revenue v. I.D.S. Ltd (2009) 8 NWLR (Pt. 1144) 615 at 639.

[30] Federal Board of Inland Revenue v. Nigerian National Supply Co. Ltd (1996) 6 NWLR (Pt. 457) 461;

[31] Cocoa Industries Ltd v. Federal Board of Inland Revenue (1986) 3 NWLR (Pt. 30) 394;

[32] Shell Petroleum Development Company of Nigeria Ltd v. Federal Board of Inland Revenue (2004) 17 NWLR (Pt.

[33] ) 345;

[34] Lagos State Board of Internal Revenue v. Eko Hotels Ltd (2017) 16 NWLR (Pt. 1591) 287; 37 Federal Inland Revenue Service v. NNPC (2018) 17 NWLR (Pt. 1643) 271.

[35] Mobil Oil (Nigeria) Ltd v. Federal Board of Inland Revenue [1977] 1 NCLR 1 at 17.

[36] NRS (Establishment) Act 2025 S. 41(F) formally under FIRS (Establishment) Act, 2007, s.61.

[37] See discussion at Part 2 above.

[38] Nigeria Revenue Service (Establishment) Act, 2025 and the Nigeria Tax Act, 2025, generally.

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