Daily Law Tips (Tip 817) by Onyekachi Umah, Esq., LL.M, ACIArb(UK)

Introduction:  

Improving internally generated revenue may include; increasing tax rates, reducing tax evasion and increasing the lawful taxation of more items/services. Although, government must provide certain services, unfortunately, government does not have adequate business to generate needed fund, so government must generate funds through taxes and levies. However, to avoid abuse among other things, laws are made to enable government to impose, demand and collect taxes, levies and penalties.

To increase internally generated revenue (and to discourage pollution), there is a new tax/levy in Abuja, the Federal Capital Territory of Nigeria. The levy (Gaseous Emission Permit Limit) by the Abuja Municipal Area Council (AMAC) seems to be targeting bakeries, industries, warehouses, bank, generators or heavy-duty, drilling, production, construction and manufacturing equipment and filling stations. This new levy is uncommon and novel to residents and companies in Abuja, hence, the avalanche of protests against the levy.

This work examines the legality of the Gaseous Emission Permit Limit Levy by Abuja Municipal Area Council (AMAC). It presents the reported demands from AMAC to residents and business in Abuja as well as the alleged legal argument/defence of AMAC for the Gaseous Emission Permit Limit Levy. In answering the question; “How lawful is the Gaseous Emission Permit Limit Levy?”, the work analyzed several laws, regulations and cases. Some of the laws and regulations analyzed, include; the Constitution of Nigeria; the Taxes and Levies (Approved List for Collection) Act 1998; the Taxes and Levies (Approved List for Collection) Act, (Amendment) Order 2015; the Federal Environmental Protection Agency Act, 1988 (now repealed); the National Environmental Standards and Regulations Enforcement Agency (Establishment) Act, 2007; the Environmental Health Officers (Registration, etc.) Act 2002; The National Environmental Health Practise Regulation 2016; and the National Environmental (Air Quality Control) Regulations 2014. Also, the landmark cases were considered; ABUJA ELECTRICITY DISTRIBUTION COMPANY (AEDC) V. KUJE AREA COUNCIL (SUIT NO. FCT/HC/CV/2030/2017) and ETI-OSA LG v. JEGEDE & ANOR (2007) LPELR-8464(CA).

The Gaseous Emission Permit Limit Levy; What it is:

It is in the public media that the Abuja Municipal Area Council (AMAC) has imposed a levy of N100,000.00 on businesses within the Area Council for Gaseous Emission Permit Limit Levy. The levy is said to focus on businesses that discharge harmful hazardous substances into the air or the land and water in Nigeria, like through the activities of industries, warehouses, bank, either from generators or heavy-duty, drilling, production, construction and manufacturing equipment, filling stations, etc. Also, the reports have it that, the failure to pay the levy, “could lead to the arrest of the operator and suspension of the bakery’s activities”.

Furthermore, AMAC is said to defend the Gaseous Emission Permit Limit Levy with the below statement; “This is in line with the provision of Section (2C) of the fourth schedule of the constitution of the Federal Republic of Nigeria as amended under the function of the Local Government Authority and Federal Environmental Protection Agency Act (FEPA) part (iii) section 25 which establish the Local Council Authority to regulate, enforce and collection of levies for the interest of public health importance (welfare) section (18), (20), (21), (26) and 27 and other relevant laws of National Environmental Health Practice Regulation 2016 which confers on the council the power to regulate, inspect, control and collection of levies/fees.”

At the time of this publication, there is no known or publicly published Bye-Law from AMAC on the the Gaseous Emission Permit Limit Levy. However, there are several demand notices from AMAC to businesses in Abuja for the Gaseous Emission Permit Limit Levy and a reported letter from AMAC defending the demand. The media has reported the levy as “the Gaseous Emission Permit Levy” and also as “the Gaseous Emission Permit Limit Levy”. Since, taxes and levies are issues that can only be created and managed by written laws, the legality of the Gaseous Emission Permit Limit Levy by AMAC will be considered below.

How lawful is the Gaseous Emission Permit Limit Levy?

Laws govern Nigeria, including the imposition, collection and demand of taxes, levies and penalties in any part of Nigeria. As such, in Nigeria, the Federal Government, the State Governments and the Local Governments (including the 6 Area Councils in the Federal Capital Territory) cannot impose, collect or demand any tax, levy or penalty, where there is no written law authorizing such. Any attempt to impose, collect or demand any tax, levy or penalty by any government, institution or person in Nigeria without any legal authority is invalid, null and void and a mere waste of resources. So, does Abuja Municipal Areas Council (AMAC) has the legal authority to impose, demand and collect the Gaseous Emission Permit Levy or Gaseous Emission Permit Limit Levy?

The legality of the AMAC’s demand for Gaseous Emission Permit Limit Levy will be analyzed in summary through on federal laws, regulations and the decisions of courts in Nigeria.

  1. Constitution of the Nigeria:

Laws are made by the legislatures in Nigeria over key issues, like taxation. In Nigeria, taxes and levies are enabled by the Constitution of the Federal Republic of Nigeria, 1999. The Constitution of Nigeria further mentioned different governments that can impose different classes/types of taxes, levies and penalties. In the Fourth Schedule to the Constitution of Nigeria, the Local Governments in Nigeria (including the 6 Area Councils in the Federal Capital Territory) have among others, the function to control and regulate shops, kiosks, restaurants, bakeries and other places for sale of food to the public, laundries and places for the sale of liquor. On this note, the Abuja Municipal Area Council (AMAC) has among its constitutional functions, the duty to regulate persons and businesses in the Abuja, that have interest in shops, kiosks, restaurants, bakeries and other places for sale of food to the public, laundries and places for the sale of liquor. This arguably covers the control and regulation of the gaseous emissions of such persons and businesses, since the Constitution did not place any limitation on the level of control and regulation to be exercised by the Local Governments and Areas Councils. As will be revealed shortly, this argument will fall where there is a federal law and agency specifically empowered to handle gaseous emission and environmental pollution, generally.

Aside the Constitution of Nigeria, the Federal Legislature has made several federal laws to further enable the imposition, collection and demand of taxes, levies and penalties by the Federal Government, State Governments and the Local Governments (including the 6 Area Councils in the Federal Capital Territory).  Among the federal laws on tax are; the Taxes and Levies (Approved List for Collection) Act 1998; the Taxes and Levies (Approved List for Collection) Act, (Amendment) Order 2015; the Personal Income Tax Act, the Companies Income Tax Act and the Finance Act.

  1. The Taxes and Levies (Approved List for Collection) Act 1998 and the Taxes and Levies (Approved List for Collection) Act, (Amendment) Order 2015:

Important to this work are the Taxes and Levies (Approved List for Collection) Act 1998 and the Taxes and Levies (Approved List for Collection) Act, (Amendment) Order 2015, which clearly lists the taxes and levies to be specifically collected by the respective three tiers of government in Nigeria (the Federal Government, State Government and the Local Government, [including the 6 Area Council in the FCT]).

By the way, the Taxes and Levies (Approved List for Collection) Act, (Amendment) Order 2015 amended the Taxes and Levies (Approved List for Collection) Act 1998 under the hand of the Federal Minister of Finance, in line with the provisions of the Taxes and Levies (Approved List for Collection) Act 1998. However, there are two (2) major conflicting judgments of the Federal High Court, on the validity of the amendment of the Taxes and Levies (Approved List for Collection) Act 1998 by a Minister (the Executive arm) instead of by the Federal Legislature. As such, the Taxes and Levies (Approved List for Collection) Act, (Amendment) Order 2015 has been validated and invalidated by the Federal High Courts in Lagos (and the appellate Courts are yet to decide on the issue).

In the case of RTHMAL vs Attorney- General of Lagos State and Federal Inland Revenue Service, the Federal High Court in Lagos State on 3 October 2019 upheld the Taxes and Levies (Approved List for Collection) Act, (Amendment) Order 2015. However, in the case of “The Registered Trustees of Hotel Owners and Managers Association of Lagos Vs. The Attorney General of the Federation & the Minister of Finance”, the Federal High Court in Lagos State, in the judgment delivered on 8 May 2020 invalidated the Taxes and Levies (Approved List for Collection) Act, (Amendment) Order 2015. Both courts are equal, as such none can overrule the other, not even the later decision. Hence, both Federal laws will be discussed here, in case any one of the laws is later found invalid by the appellate courts.

The Taxes and Levies (Approved List for Collection) Act 1998 empowers Local Governments (including AMAC and other Area Councils in the Federal Capital Territory [FCT]) to collect taxes and levies from shops, kiosks, restaurants, places for the sale of liquor, slaughter slabs, markets (not owned by State Government), motor parks, public convivence, sewage and refuse disposal. Obviously, by this Act, AMAC has the legal authority to collect taxes and levies from specific businesses with investments or focus in the above-mentioned areas within Abuja. However, it never mentioned environmental, ecological and gaseous emissions as a type of tax/levy to be collected by any Local Government or Area Council.

On the other hand, the Taxes and Levies (Approved List for Collection) Act, (Amendment) Order 2015 expanded the taxes and levies to be collected by the governments in Nigeria, by creating new taxes and levies. It added “Wharf Landing Charge” to the tax and levy to be collected by Local Governments and Area Councils that have such facilities. However, it clearly created “Environmental (Ecological) fee or Levy” among others as one of the new taxes and levies to be collected by the State Governments (in the case of the FCT, by the Federal Capital Territory Authority). Hence, under this law, Local Governments and Area Councils (including the AMAC) lack the power to collect “Gaseous Emission Permit Limit Levy” rather it is the State Governments and the Federal Capital Territory Authority that can collect such.

  1. The Federal Environmental Protection Agency Act, 1988:

It is reported in the public media (the Punch Newspaper) that; “In a letter by the Head of Environment, AMAC, Ahmed Haruna”, AMAC relies on some federal laws in imposing the Gaseous Emission Permit Limit Levy, including the Federal Environmental Protection Agency Act (particularly, its section 25). Hence, it is important to review the Federal Environmental Protection Agency Act.

Section 25 of the Federal Environmental Protection Agency Act, provided that; “The President shall, as soon as possible after the commencement of this Act, encourage States and local government councils to set up their own environmental protection bodies for the purpose of maintaining good environmental quality in the areas of related pollutants under their control, subject to the provisions of this Act.”

The provisions of section 25 of the Federal Environmental Protection Agency Act, would have been a good basis for any State Government, Local Government or Area Council (like AMAC) to create a good environmental agency. Unfortunately, the Federal Environmental Protection Agency Act is invalid, nullified, repealed and dead since 30 July 2007. It was repealed by section 36 of the National Environmental Standards and Regulations Enforcement Agency (Establishment) Act, 2007 (this federal law is discussed below). Hence, AMAC has no authority to rely on the Federal Environmental Protection Agency Act in imposing the Gaseous Emission Permit Levy, since there is no such law.

Assuming that the Federal Environmental Protection Agency Act is still valid, it does not seem to be a good authority for AMAC to impose any tax or levy (the Gaseous Emission Permit Levy). The repealed the Federal Environmental Protection Agency Act in its forty-two (42) sections never contemplated or provided for tax/levy rather provided fines and imprisonment for criminal breach of environmental protection regulations. Since, there is no valid law known as the Federal Environmental Protection Agency Act, the AMAC cannot rely on a non-existing law to impose the Gaseous Emission Permit Levy.

  1. The National Environmental Standards and Regulations Enforcement Agency (Establishment) Act, 2007:

The National Environmental Standards and Regulations Enforcement Agency (Establishment) Act, 2007 is a federal legislation that established the National Environmental Standards and Regulations Enforcement Agency (NESREA). It also oversees the protection and development of the environment in Nigeria. It repealed the Federal Environmental Protection Agency Act, 1988.

The National Environmental Standards and Regulations Enforcement Agency has the powers to “… enforce compliance with laws, guidelines, policies and standards on environmental matters” and to “… enforce compliance with policies, standards, legislation and guidelines on water quality, environmental health and sanitation, including pollution abatement” in any part of Nigeria. Its function includes; “… control of atmospheric pollution originating from energy sources, including that produced by aircraft and other self-propelled vehicles, industries, factories and power generating situations or facilities”. The National Environmental Standards and Regulations Enforcement Agency (Establishment) Act, 2007 criminalizes the violation of regulations on air quality and atmospheric condition and made it punishable with fine or imprisonment or both.

Although, the National Environmental Standards and Regulations Enforcement Agency (Establishment) Act, 2007 expressly provides that NESREA can corporate and collaborate with other government agencies and stakeholder. The National Environmental Standards and Regulations Enforcement Agency (Establishment) Act, 2007 is silent on the roles of the State Governments, Local Governments (including Area Councils) in the protection and development of the environment. To this extent, the imposition of the Gaseous Emission Permit Levy for the discharge harmful hazardous substances into the air or the land and water in Nigeria by the Abuja Municipal Area Council (AMAC) may be a usurpation of federal law and the powers of NESREA.

  1. The Environmental Health Officers (Registration, etc.) Act 2002:

The Abuja Municipal Area Council (AMAC) is reported to also rely on “…section (18), (20), (21), (26) and 27 and other relevant laws of National Environmental Health Practice Regulation 2016 which confers on the council the power to regulate, inspect, control and collection of levies/fees” as the basis for its demand for Gaseous Emission Permit Levy. Well, to better understand the National Environmental Health Practice Regulation 2016, it is advisable to understand its parent law (the Environmental Health Officers (Registration, etc.) Act 2002).

The Environmental Health Officers (Registration, etc.) Act 2002 is a federal law that establishes the Environmental Health Officers Registration Council of Nigeria, for the regulation of Environmental Health Officers and the control of the practice of the profession of Environmental Health in Nigeria. The Environmental Health Officers Registration Council of Nigeria sets standards for Environmental Health Officers in Nigeria, it maintains a register of such officers, conducts professional examinations and awards certificates. The twenty-eight (28) sections of the Environmental Health Officers (Registration, etc.) Act 2002 focus on the admission of Environmental Health Officers by the Council and regulation of the conducts of Environmental Health officers. However, relying on the Environmental Health Officers (Registration, etc.) Act 2002, a federal regulation (the National Environmental Health Practise Regulation 2016) was made by the Federal Minister for Environment on 10 February 2016.

Clearly, the Environmental Health Officers (Registration, etc.) Act 2002 does not make any provisions for the Abuja Municipal Area Council or for the imposition of any Gaseous Emission Permit Levy by AMAC. Rather, it oversees the registration and practice of Environmental Health Officers in all parts of Nigeria, including in Abuja.

  1. The National Environmental Health Practise Regulation 2016:

The National Environmental Health Practise Regulation 2016 is a subsidiary legislation (regulation) made pursuant to the Environmental Health Officers (Registration, etc.) Act 2002 to provide guideline for the enforcement of the regulatory powers of the Environmental Health Officers Registration Council of Nigeria. It is to prevents nuisance, reduce environmental hazards and it applies to all parts of Nigeria, including Abuja. It provides for fines and imprisonment for any person or business that contravenes any Environmental Protection Regulations or Guidelines.

Regulation 107 of the  National Environmental Health Practise Regulation 2016 interprets Environmental Health Authorities to include the government departments responsible for Environmental Health Services (including the Federal Government, State Governments and the Local Governments). Regulation 80 of the of the National Environmental Health Practise Regulation 2016 mandates all governments to enforce the National Air Quality Standards issued by the Federal Ministry of Environment. This includes the Motor Vehicle/Motorcycle Emission Limit Permit. It also provides that an industry may be declared to by an air polluter by the Federal Minister of Environment and such industry must ensure that its pollution is within the permissible limit. The violation of the provisions of the Regulation is punishable with fine of not more than N50,000 for individuals and N250,000.00 for corporate bodies, after being convicted by a court.    

By this, the Abuja Municipal Area Council (AMAC) has legal authority to create a department for Environmental Health Services and to enforce the National Air Quality Standards. However, it is the Federal Minister of Environment that has the powers to declare an industry/business to be an air polluter and to demand for the maintenance a minimum permissible limit. Hence, the alleged demand by AMAC for businesses to pay N100,000.00 for Gaseous Emission Permit Levy seems to be out of place and not contemplated by the National Environmental Health Practise Regulation 2016. The National Environmental Health Practise Regulation 2016 has room for fines and imprisonment upon conviction by court and not the administrative imposition of levies.

In the alleged letter from AMAC, the Area Council relies on “…section (18), (20), (21), (26) and 27 and other relevant laws of National Environmental Health Practice Regulation 2016…” for the imposition of Gaseous Emission Permit Levy. Unfortunately, all the above stated sections cited by AMAC, merely focus on the collection and disposal of solid waste and not on Gaseous Emission Permit Levy. Hence, while AMAC can rely on the aid sections to dispose solid waste, AMAC cannot rely on them for any gaseous waste. Issues of gaseous emissions are provided for in sections (regulations) 80 to 83 and those not contemplate the role of Local Governments and Area Councils (including AMAC). Hence, the reliance placed by AMAC on the sections (18), (20), (21), (26) and 27 to impose Gaseous Emission Permit Levy is unfounded and invalid.

By the way, the writer believes that the Environmental Health Officers (Registration, etc.) Act 2002 has no powers to sustain the regulatory powers created by the National Environmental Health Practise Regulation 2016. The provisions of the National Environmental Health Practise Regulation 2016 are beyond the powers of the Environmental Health Officers Registration Council of Nigeria enshrined in the Environmental Health Officers (Registration, etc.) Act 2002. In making the National Environmental Health Practise Regulation 2016 under the Environmental Health Officers (Registration, etc.) Act 2002, the Federal Minister of Environment acted beyond his powers, by adding to the subsidiary legislation, matters that are beyond and not contemplated by its parent legislation. The extenders and seeming broad terms used in the Environmental Health Officers (Registration, etc.) Act 2002 cannot be source and permission for an Executive to amend the legislations of the federal legislature.

  1. The National Environmental (Air Quality Control) Regulations 2014:

The National Environmental (Air Quality Control) Regulations 2014 is a federal regulation made pursuant to the National Environmental Standards and Regulations Enforcement Agency (Establishment) Act, 2007. It is designed to improve national air quality and ensure access to clean air. It prohibits the installation of certain equipment in the residential areas; burning; two-stroke engines; mobile sources of emission; indoor air pollution; banned pesticides; some location of power generating sets; and the smoking in public places, among others. It sets minimum permissible limits and criminalizes violations, punishable with fines or imprisonment or both.

The Regulation 107 of the National Environmental Health Practise Regulation 2016 empowers all governments in Nigeria to enforce the National Environmental Regulations, including the National Environmental (Air Quality Control) Regulations 2014. To this end, the Abuja Municipal Area Council (AMAC) can enforce the National Environmental (Air Quality Control) Regulations 2014. However, the National Environmental (Air Quality Control) Regulations 2014 made provisions for fines and imprisonments, where there is a violation. The National Environmental (Air Quality Control) Regulations 2014 does not cover the imposition and demand for taxes ad levies for Gaseous Emission Permit Levy. Consequently, the AMAC imposition of the Gaseous Emission Permit Levy cannot rely on the National Environmental (Air Quality Control) Regulations 2014.

  1. Case Law 1: ABUJA ELECTRICITY DISTRIBUTION COMPANY (AEDC) V. KUJE AREA COUNCIL (SUIT NO. FCT/HC/CV/2030/2017):

There are decisions of courts in Nigeria that are key to this inquiry on the legality of AMAC Gaseous Emission Permit Levy. Recently, on 14 January 2019, the High Court of the Federal Capital Territory ruled in the case of Abuja Electricity Distribution Company (AEDC) v. Kuje Area Council (SUIT NO. FCT/HC/CV/2030/2017), that Area Council or Local Government cannot amend the list of taxes and levies duly contained in the Fourth Schedule to the Constitution of Nigeria, the Taxes and Levies (Approved List for Collection) Act 1998 and the Taxes and Levies (Approved List for Collection) Act, (Amendment) Order 2015.

Hence, by the Constitution of Nigeria and the Taxes and Levies (Approved List for Collection) Act 1998 and the Taxes and Levies (Approved List for Collection) Act, (Amendment) Order 2015, no Local Government or Area Council can impose or demand a new class or type of tax (the Gaseous Emission Permit Levy). On this note, the Abuja Municipal Area Council has no powers whatsoever, to impose or demand for the payment of Gaseous Emission Permit Levy from any person or business.

  1. Case Law 2: ETI-OSA LG v. JEGEDE & ANOR (2007) LPELR-8464(CA):

The above decision of the High Court of the FCT in the case of Abuja Electricity Distribution Company (AEDC) v. Kuje Area Council (SUIT NO. FCT/HC/CV/2030/2017), relies on the case of ETI-OSA LG v. JEGEDE & ANOR (2007) LPELR-8464(CA).

The defining words of the Court of Appeal in ETI-OSA LG v. JEGEDE & ANOR (2007) LPELR-8464(CA), are very key. They are reproduced here: “To leave taxation at large at the whim and caprice of the different tiers of government would expose the entire citizenry to undue multiple and over lapping taxes and levies. Taxation should be a tool of social engineering, of societal class structural adjustment in the hands of a responsive and sensitive government…. The Appellant has no inherent powers to legislate nor create and impose taxes outside the scope of Decree No. 21 of 1998 nor the 4th schedule of the 1999 Constitution.” Per MONICA BOLNA’AN DONGBAN-MENSEM, J.C.A.

Conclusion:

The dwindling crude oil prices across the world has woken the need for diversification of Nigeria’s economy. Increasing internally generated revenue has glued to the lips of government spokespersons. Governments are eager to increase taxes and levies, however, even at the risk of violating laws. Arguably, this has prompted the recent imposition and demand for the Gaseous Emission Permit Levy by the Abuja Municipal Area Council (AMAC).

No matter how just and unjust, beneficial to government or the public, innovative or not, that any tax or levy may seem, it will never be lawfully enforceable, unless there is a written legal authority for it. While AMAC may have statutory powers to regulate air pollution in Abuja and to also regulate certain specific affairs of individuals and businesses in AMAC, there is no legal authority for AMAC to impose or demand the alleged Gaseous Emission Permit Levy. Persons who violate the National Environmental (Air Quality Control) Regulations 2014 are to pay fines or be imprisoned after being convicted by a court of law. There is no provision in the National Environmental (Air Quality Control) Regulations 2014 or any other known law that validates AMAC’s Gaseous Emission Permit Levy. There cannot be a payment for a Gaseous Emission Permit Levy where there is no prove of such emission and an order of court indicting the owner of the business or equipment responsible for the emission. AMAC should in line with the National Environmental (Air Quality Control) Regulations 2014 focus on avoiding and reducing emission as well as prosecuting offenders, instead of seeking to administratively demand unlawful levies.

More importantly, Gaseous Emission Permit Levy is not one of the statutorily listed taxes and levies that a Local Government or Area Council in Nigeria can impose, demand and collect. Relying on the decision of the Court of Appeal in the case of ETI-OSA LG v. JEGEDE & ANOR (2007) LPELR-8464(CA), AMAC lacks the powers and authority to impose, demand and collect any tax or levy, titled; Gaseous Emission Permit Levy or Gaseous Emission Permit Limit Levy or any other new tax head/title.

My authorities, are:

  1. Sections 1, 2, 3, 4, 5, 6, 7, 318 and 319 and the Fourth Schedule to the Constitution of the Federal Republic of Nigeria, 1999.
  2. Sections 4(5), 7(5), Paragraphs 7, 8 and 9, Part II of Second Schedule and Paragraph 1(J) of the Fourth Schedule to the Constitution of the Federal Republic of Nigeria, 1999.
  3. Sections 2 and 5 as well as the Schedule to the Taxes and Levies (Approved List for Collection) Act, 1998 and the Schedule to the Taxes and Levies (Approved List for Collection) Act, (Amendment) Order 2015.
  4. Sections 1 to 37 of the National Environmental Standards and Regulations Enforcement Agency (Establishment) Act, 2007
  5. Sections 1 to 29 of the Environmental Health Officers (Registration, etc.) Act 2002
  6. Regulations 1 to 42 of the National Environmental (Air Quality Control) Regulations 2014.
  7. Sections 1 to 42 of the Federal Environmental Protection Agency Act 1988 (REPEALED since 2007)
  8. The judgment of the Court of Appeal (on whether Local Government or Area Council can impose tax outside the Constitutional Provisions) in the case of ETI-OSA LG v. JEGEDE & ANOR (2007) LPELR-8464(CA)
  9. The judgment of the High Court of the Federal Capital Territory (on whether Local Government or Area Council can impose tax outside the Constitutional Provisions) in the case of ABUJA ELECTRICITY DISTRIBUTION COMPANY (AEDC) V. KUJE AREA COUNCIL (SUIT NO. FCT/HC/CV/2030/2017)
  10. Lucy Adegbe, “Confusion as AMAC tax bakery owners N100,000 as fees for ‘gaseous emission” (TheStreetJournal, 21 July 2021) <https://thestreetjournal.org/confusion-as-amac-tax-bakery-owners-n100000-as-fees-for-gaseous-emission/> accessed 29 July 2021.
  11. Samuel Akpan, “AMAC asks bakers to pay N100K for ‘gaseous emission permit’” (LearnNigerianLaws.com, 20 July 2021) <https://www.thecable.ng/amac-asks-bakers-to-pay-n100k-for-gaseous-emission-permit> accessed 29 July 2021.
  12. Solomon Adeniyi, “Outrage as Abuja council slams N100,000 levy on firms using generators, machines” (Punch, 24 July 2021) <https://punchng.com/outrage-as-abuja-council-slams-n100000-levy-on-firms-using-generators-machines/> accessed 29 July 2021.
  13. Onyekachi Umah, “When Must Online Businesses and Entities Pay Tax in Nigeria?” (LearnNigerianLaws.com, 13 July 2021) <https://learnnigerianlaws.com/when-must-online-businesses-and-entities-pay-tax-in-nigeria/> accessed 2 August 2021
  14. Onyekachi Umah, “NIGERIANS MUST PAY TAX ON INCOMES MADE ABROAD FROM ANY SOURCE AND FAILURE TO DO SO IS AN OFFENCE” (com, 11 October 2011) <https://learnnigerianlaws.com/nigerians-must-pay-tax-on-incomes-made-abroad-from-any-source-and-failure-to-do-so-is-an-offence-daily-law-tips-tip-433-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2021.
  15. Onyekachi Umah, “CAN TAX OFFICE UNILATERALLY IMPOSE PERCENTAGES OF TURNOVER AS ANY PERSON’S INCOME TAX” (com, 19 September 2019) <https://learnnigerianlaws.com/can-tax-office-unilaterally-impose-percentages-of-turnover-as-any-person-s-income-tax-daily-law-tips-tip-417-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2021.
  16. Onyekachi Umah, “WHEN CAN A VILLAGE/COMMUNITY IN NIGERIA BE CHARGED PERSONAL INCOME TAX” (com, 13 September 2019) <https://learnnigerianlaws.com/when-can-a-village-community-in-nigeria-be-charged-personal-income-tax-daily-law-tips-tip-414-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2021.
  17. Onyekachi Umah, “BUSINESSES AND COMPANIES IN NIGERIA CANNOT PAY PERSONAL INCOME TAX” (com, 10 September 2019) <https://learnnigerianlaws.com/businesses-and-companies-in-nigeria-cannot-pay-personal-income-tax-daily-law-tips-tip-411-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2021.
  18. Onyekachi Umah, “WHEN CAN A FAMILY BE CHARGED PERSONAL INCOME TAX” (com, 29 August 2019) <https://learnnigerianlaws.com/when-can-a-family-be-charged-personal-income-tax-daily-law-tips-tip-403-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2021.
  19. Onyekachi Umah, “WHEN CAN PROPERTY OF A DECEASED PERSON PAY PERSONAL INCOME TAX” (com, 23 August 2019) <https://learnnigerianlaws.com/when-can-property-of-a-deceased-person-pay-personal-income-tax-daily-law-tips-tip-398-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2021.
  20. Onyekachi Umah, “BUSINESS NAMES IN NIGERIA CANNOT PAY PERSONAL INCOME TAX” (com, 20 August 2019) <https://learnnigerianlaws.com/business-names-in-nigeria-cannot-pay-personal-income-tax-daily-law-tips-tip-396-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2021.
  21. Onyekachi Umah, “DEADLINES FOR PAYMENT OF PERSONAL INCOME TAX BY SELF EMPLOYED PERSONS AND EMPLOYEES” (com, 6 August 2019) <https://learnnigerianlaws.com/deadlines-for-payment-of-personal-income-tax-by-self-employed-persons-and-employees-daily-law-tips-tip-388-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2021.
  22. Onyekachi Umah, “WHEN PERSONS RESIDING ABROAD MUST PAY PERSONAL INCOME TAX TO NIGERIA” (com, 31 July 2019) <https://learnnigerianlaws.com/when-persons-residing-abroad-must-pay-personal-income-tax-to-nigeria-daily-law-tips-tip-384-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2021
  23. Onyekachi Umah, “DURATION FOR ISSUANCE OF TAX CLEARANCE CERTIFICATE IN NIGERIA” (com, 30 July 2021) <https://learnnigerianlaws.com/duration-for-issuance-of-tax-clearance-certificate-in-nigeria-daily-law-tips-tip-383-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2021.
  24. Onyekachi Umah, “THINGS YOU CANNOT DO IN NIGERIA WITHOUT A TAX CLEARANCE CERTIFICATE” (com, 17 July 2019) <https://learnnigerianlaws.com/things-you-cannot-do-in-nigeria-without-a-tax-clearance-certificate-daily-law-tips-tip-373-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2021
  25. Onyekachi Umah, “PUNISHMENT FOR FAILURE TO PAY PENALTY FOR NON-PAYMENT OF PERSONAL INCOME TAX” (com, 8 May 2019) <https://learnnigerianlaws.com/punishment-for-failure-to-pay-penalty-for-non-payment-of-personal-income-tax-daily-law-tips-tip-326-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2019
  26. Onyekachi Umah, “PENALTY FOR NON-PAYMENT OF PERSONAL INCOME TAX” (com, 2 may 2019) <https://learnnigerianlaws.com/penalty-for-non-payment-of-personal-income-tax-daily-law-tips-tip-322-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 12 July 2021
  27. Onyekachi Umah, “NO PERSON/FIRM CAN COLLECT TAX/LEVY ON BEHALF OF ANY GOVERNMENT IN ANY PART NIGERIA” (com, 2 march 2019) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-279-no-person-firm-can-collect-tax-levy-on-behalf-of-any-government-in-any-part-nigeria/> accessed 12 July 2021.
  28. Onyekachi Umah, “EDUCATION TAX MUST BE PAID YEARLY BY EVERY COMPANY IN NIGERIA” (com, 20 November 2018) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-231-education-tax-must-be-paid-yearly-by-every-company-in-nigeria/> accessed 12 July 2021
  29. Onyekachi Umah, “Monthly Deadline For Filling Returns On Value Added Tax (VAT)” (com, 2 August 2018) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-155-monthly-deadline-for-filling-returns-on-value-added-tax-vat/> accessed 12 July 2021
  30. Onyekachi Umah, “Value Added Tax (VAT); Who Pays and Who Collects” (com, 13 July 2018) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-141-value-added-tax-vat-who-pays-and-who-collects/> accessed 12 July 2021
  31. Onyekachi Umah, “Is there a Reduction of Levy for Imported Cars and Trucks?” (com, 22 March 2021) <https://learnnigerianlaws.com/is-there-a-reduction-of-levy-for-imported-cars-and-trucks/> accessed 12 July 2021
  32. Onyekachi Umah, “Does the New Finance Act Exempt Companies from CAC Annual Returns?” (com, 17 March 2021) <https://learnnigerianlaws.com/does-the-new-finance-act-exempt-companies-from-cac-annual-returns/> 12 July 2021
  33. Onyekachi Umah, “RADIO, TELEVISION AND COMMUNICATION MAST LICENSE FEE BY LOCAL GOVERNMENTS IN NIGERIA” (com, 5 March 2020) <https://learnnigerianlaws.com/radio-television-and-communication-mast-license-fee-by-local-governments-in-nigeria-daily-law-tips-tip-519-by-onyekachi-umah-esq-llm-aciarbuk/> accessed 12 July 2021
  34. Onyekachi Umah, “LATEST DEVELOPMENTS ON LIQUOR LICENSES IN KARU LGA, NASARAWA STATE” (com, 28 February 2020) <https://learnnigerianlaws.com/latest-developments-on-liquor-licenses-in-karu-lga-nasarawa-state-daily-law-tips-tip-515-by-onyekachi-umah-esq-llm-aciarbuk/> accessed 12 July 2021
  35. Onyekachi Umah, “LIST AND DETAILS OF APPROVED LOCAL GOVERNMENT LEVIES, RATES, FEES AND CHARGES FOR EDO STATE” (com, 27 September 2019) <https://learnnigerianlaws.com/list-and-details-of-approved-local-government-levies-rates-fees-and-charges-for-edo-state-daily-law-tips-tip-423-by-onyekachi-umah-esq-llm-aciarb-uk-2/> accessed 12 July 2021
  36. Onyekachi Umah, “STATE GOVERNMENTS CANNOT COLLECT TENEMENT RATES IN NIGERIA” (com, 6 March 2019) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-282-state-governments-cannot-collect-tenement-rates-in-nigeria/> accessed 12 July 2021
  37. Onyekachi Umah, “Is It Legal For Government Or Any Group To Charge You For Drilling Borehole On Your Land” (com, 29 November 2018) <https://learnnigerianlaws.com/is-it-legal-for-government-or-any-group-to-charge-you-for-drilling-borehole-on-your-land/> accessed 12 July 2021
  38. Onyekachi Umah, “Right To Demand and Know How Much Government and Government Officers Spend In Nigeria” (com, 29 August 2018) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-172-right-to-demand-and-know-how-much-government-and-government-officers-spend-in-nigeria/> accessed 12 July 2021
  39. Onyekachi Umah, “Goods That Are Exempted From VAT Payment In Nigeria” (com, 16 August 2018) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-164-goods-that-are-exempted-from-vat-payment-in-nigeria/> accessed 12 July 2021
  40. Onyekachi Umah, “What is Ground Rent, Who Should Pay and Who Should Collect It?” (com, 26 June 2018) <https://learnnigerianlaws.com/what-is-ground-rent-who-should-pay-and-who-should-collect-it/> accessed 12 July 2021
  41. Onyekachi Umah, “What is Tenement Rate, Who Should Pay and Who Collects” (com, 21 June 2018) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-125-what-is-tenement-rate-who-should-pay-and-who-collects/> accessed 12 July 2021.
  42. Onyekachi Umah, “Payment of Annual Development Levy by Abuja Residents” (com, 8 April 2018) <https://learnnigerianlaws.com/payment-of-annual-development-levy-by-abuja-residents> accessed 12 July 2021.
  43. Onyekachi Umah, “Inapplicability of the Tenement Rates in Abuja” (LearnNigerianLaws.com, 20 April 2018) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-85-inapplicability-of-tenements-rate-in-abuja/> accessed 2 August 2021
  44. Onyekachi Umah, “Summary of 2018 Budget of the Federal Government of Nigeria” (LearnNigerianLaws.com, 22 June 2018) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-126-summary-of-2018-budget-of-the-federal-government-of-nigeria/> accessed 2 August 2021
  45. Onyekachi Umah, “The Presidency Has No Powers To Increase VAT in Nigeria” (LearnNigerianLws.com, 1 October 2019) <https://learnnigerianlaws.com/the-presidency-has-no-powers-to-increase-vat-in-nigeria-daily-law-tips-tip-426-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 2 August 2021
  46. Onyekachi Umah, “List AND DETAILS OF APPROVED LOCAL GOVERNMENT LEVIES, RATES, FEES AND CHARGES FOR EDO STATE” (LearnNigerianLaws.com, 27 September 2019) <https://learnnigerianlaws.com/list-and-details-of-approved-local-government-levies-rates-fees-and-charges-for-edo-state-daily-law-tips-tip-423-by-onyekachi-umah-esq-llm-aciarb-uk-2/> accessed 2 August 2021
  47. Onyekachi Umah, “Six Duties of All Nigerians In Any Part of the World” (LearnNigeriansLaws.com, 28 August 2019) <https://learnnigerianlaws.com/six-duties-of-all-nigerians-in-any-part-of-the-world-daily-law-tips-tip-402-by-onyekachi-umah-esq-llm-aciarb-uk/> accessed 2 August 2021
  48. Onyekachi Umah, “IS IT LEGAL FOR GOVERNMENT OR ANY GROUP TO CHARGE YOU FOR DRILLING BOREHOLE ON YOUR LAND?” (LearnNigerianLaws.com, 29 November 2018) <https://learnnigerianlaws.com/is-it-legal-for-government-or-any-group-to-charge-you-for-drilling-borehole-on-your-land/> accessed 2 August 2021

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