Paper World Nigeria Limited, Ibadan, a manufacturer of paper pulp, paper, and paperboard, was granted a pioneer certificate by the Federal Government on May 1, 2017, for an initial period of three years. Due to unfavorable business conditions and interference by the Ministry of Industry on dividend policy, loss treatment, and capital allowances, the company did not apply for an extension to the pioneer status.

The company’s financial statements for the first three years are as follows:

(i) Financial Data for the Years Ended

Year End April 30, 2018 April 30, 2019 April 30, 2020
N’000 N’000 N’000
Net loss (28,700) (25,500) (20,200)
After charging:
Salaries and wages 15,300 16,100 17,360
Transport and traveling 1,100 1,700 1,820
Depreciation 6,800 7,530 8,600
Rent and rates 1,200 1,400 1,500
Donations to social clubs 100 0 250
Allowance for doubtful debts:
Specific 1,400 1,200 1,500
General 1,850 1,750 1,800
General expenses 1,650 1,820 1,900

(ii) Qualifying Capital Expenditure (QCE) Certified by FIRS at Pioneer Period End

(iii) Additional QCE Acquired:

QCE Number of Items Amount (N’000) Date of Acquisition
Furniture and fittings 2 500 June 12, 2020
Motor vehicles 1 2,200 March 7, 2021

(iv) Operational Result (April 30, 2021)

Description N’000
Turnover 102,500
Dividend income (grossed up) 1,200
Other operating income 800
Total 104,500
Deductions:
Salaries and wages 39,600
Repairs and maintenance 3,500
Depreciation 15,300
Rents and rates 6,800
General and administrative expenses 9,970
Legal fees 2,500
Audit and accountancy fees 3,200
Allowance for doubtful debts 6,600
Bank charges 2,100
Net profits 14,930

Additional Information:

  • Dividend Income: From equity shares in a Nigerian listed company.
  • QCE Acquisitions:
    • Non-industrial building: N10,000
    • Industrial building: N25,600
    • Manufacturing industrial plants: N12,600
    • Furniture and fittings: N3,400
    • Motor vehicles: N4,000

(vi) Repairs and Maintenance Breakdown:

Category Amount (N’000)
Manufacturing plant repairs 1,500
Motor vehicle maintenance 800
Non-industrial building improvement 1,200

(vii) General and Administrative Expenses:

Category Amount (N’000)
Transport and traveling 3,750
Advertisement 4,920
Transfer to revenue reserve 1,300

(viii) Legal Fees Breakdown:

Category Amount (N’000)
Collection of trade debts 1,100
Fine for late tax filing 50
Legal expenses on new share issue 1,350

(ix) Doubtful Debts Allowance Breakdown:

Category Amount (N’000)
Bad debts written off 2,800
Specific provision 2,500
General provision 3,700
Bad debts recovered (2,400)

Required: As the company’s newly appointed Tax Consultant, prepare a report to the Managing Director stating the:

  1. Adjusted Profits for the Relevant Periods (13 Marks)
  2. Tax Liabilities Payable for the Relevant Assessment Year (11 Marks)
  3. Provisions of the Industrial Development (Income Tax Relief) Act 2007 (as amended) in respect of a Pioneer Company’s:
    • i. Dividend Payment (2 Marks)
    • ii. Losses Made During the Pioneer Period (2 Marks)
    • iii. Capital Allowances for Qualifying Capital Expenditure Acquired During the Pioneer Period (2 Marks)

BFN & Co (Tax Consultants)
9, Alabata Road, Abeokuta

Date:

To: The Managing Director
Paper World Nigeria Limited
2, Oyo-Ogbomoso Road, Ibadan.

Subject: Computation of Adjusted Profits, Tax Liabilities, and Other Tax Matters

a. Adjusted Profits

During the pioneer period (2018, 2019, and 2020), Paper World Nigeria Limited recorded a total adjusted loss of N45,720,000. Detailed breakdown:

  • Year Ended April 30, 2018: Adjusted Loss N19,950,000
  • Year Ended April 30, 2019: Adjusted Loss N16,220,000
  • Year Ended April 30, 2020: Adjusted Loss N9,550,000

For the year ended April 30, 2021, the adjusted profit amounted to N36,630,000.

b. Tax Liabilities Payable for 2022 Assessment Year

Given the absence of total profit, the company has no companies income tax liability. However, it is liable for Tertiary Education Tax at 2.5% of the assessable/adjusted profit, totaling N915,750. Since the company has been operational for less than 48 months, it is exempt from minimum tax.

Management should file the annual tax return promptly and include a cheque of N915,750 to the Federal Inland Revenue Service (FIRS).

c. Provisions of the Industrial Development (Income Tax Relief) Act 2007 (as amended)

  1. Dividend Payment
    Dividends can be declared tax-free from pioneer profits. Dividend distribution is restricted to the balance on the profit and loss account.
  2. Losses During the Pioneer Period
    Losses certified by the FIRS may be carried forward and relieved in the first year of new trade. Unrelieved losses at the end of the first year lapse permanently.
  3. Capital Allowances
    Qualifying capital expenditures from the pioneer period are aggregated and treated as incurred on the first day of the new trade, qualifying for initial and annual allowances from the first assessment year of the new trade​