Debby Oil Limited is an oil prospecting company that has been operating in the deep ocean of the Niger Delta since 1990. The company makes up its accounts to December 31 each year.

The company is in discussion with a consortium of five deposit money banks in Nigeria for the purposes of taking a medium-term (5 years) loan facility of USD 5 million to finance further expansion of its facilities and acquisition of a marginal field. As part of the documents required by the banks for processing the loan facility are the audited financial statements and tax computations for the last five financial years. The company is yet to submit the documents for the year ended December 31, 2020, to the consortium.

The extract from its activities for the year ended December 31, 2020, is as presented below:

Item Amount (₦’000)
Oil inventory (Jan 1, 2020) 1,220,000
Oil inventory (Dec 31, 2020) 1,380,000
Sales – Export 9,524,000
Sales – Local 2,900,500
Other income 1,235,300
Production cost 3,440,000
Operating expenses 1,789,600
Intangible drilling cost 1,425,200
Tangible drilling cost 532,000
Traveling expenses 54,000
Salaries and wages 1,860,000
Pension fund contribution 175,000
Loan interest 150,000
General expenses 800,500
Depreciation 170,000
Royalties and production rentals 810,000
Donation 20,000
Bank charges 25,300
Harbour dues 15,000
Non-productive rent 350,000
Audit and accountancy fees 28,000
Customs duty on essentials 7,300
Income tax provision 865,860
Transfer to general reserves 900,000

Additional Information:

  1. Posted prices of crude oil exported is USD 35 per barrel at the standard API gravity of 32°.
  2. Actual realised price is adjusted for deviation from the standard API gravity. Each degree change in API results in a price adjustment of USD 0.20.
  3. 650,000 barrels of crude oil were exported during the year with an API gravity of 34°.
  4. Other income of ₦735 million was generated from the company’s ocean tanker business. Associated expenses of ₦580.5 million were included in general expenses.
  5. Operating expenses included ₦9 million for short lease renewal.
  6. Pension fund contributions were approved by the State Internal Revenue Service.
  7. Loan interest included ₦78 million paid to a subsidiary company, approved by the board.
  8. A new pipeline and storage tank costing ₦150 million was acquired for offshore operations in a 180-meter deep area.
  9. Transfer to general reserves was board-approved.
  10. Capital allowances agreed with the tax authorities include an annual allowance of ₦120 million and a balancing charge of ₦8 million.
  11. Assume USD 1 is equivalent to ₦420.

Required:
As the company’s Assistant Tax Manager, draft a report to the Tax Manager showing the company’s tax liability for the relevant assessment year according to the Petroleum Profits Tax Act, Cap P.13, Laws of the Federation of Nigeria 2004 (as amended).

Subject: COMPUTATION OF TAX LIABILITY FOR 2020 YEAR OF ASSESSMENT

Memo Date: April 1, 2021
From: Assistant Tax Manager
To: Tax Manager

I have completed the tax liability computation for Debby Oil Limited, with the following results:

The total tax liability for the year ended December 31, 2020, is ₦2,132,004,000, comprising:

  1. Chargeable Tax: ₦2,080,208,000
  2. Tertiary Education Tax: ₦51,796,000

A detailed schedule outlining the tax liability calculation is attached for your review.

Please reach out if any further details or clarifications are required.

Best regards,
Segge Oshah
Assistant Tax Manager

SCHEDULE OF COMPUTATION OF TAX LIABILITY

Debby Oil Limited
Computation of Tax Liability
For 2020 Year of Assessment

Workings