Engineer Kole Ahmed manages a wholly owned Nigerian engineering outfit – Oduifa Construction Company Limited, based at Ikeja and incorporated in February 2010.

Given the challenging economic environment in Nigeria and inconsistent government policies, the company’s management embarked on foreign diversification of income. They sourced and secured some contracts in the United Kingdom where they have operational activities in London.

Extracts from the Statement of Profit or Loss for the year ended December 31, 2015, for Lagos and London operations, are as follows:

Description Lagos (N) London (N) Global (N)
Revenue 68,000,000 70,200,000 138,200,000
Direct expenses (43,410,000) (44,050,000) (87,460,000)
Gross profit 24,590,000 26,150,000 50,740,000
Administrative expenses:
– Staff salaries 1,200,000 1,440,000 2,640,000
– Rent and rates 840,000 960,000 1,800,000
– Motor vehicle expenses 136,000 148,000 284,000
– Repairs and maintenance 92,000 106,500 198,500
– Utilities 76,840 81,000 157,840
– Business insurances 55,000 60,000 115,000

Capital allowances: N725,000.

Required: Compute the final tax liability of the company for the relevant assessment year. (15 Marks)

Computation of Final Tax Liability for Oduifa Construction Ltd.

  1. Adjusted Assessable Profit:
    • Net Profit per Accounts:
      • Lagos: N20,615,160
      • London: N17,288,500
    • Adjustments:
      • Disallowable foreign tax suffered: N4,260,000 (London)
      • Depreciation: N860,000 (Lagos) + N920,000 (London) = N1,780,000
  2. Capital Allowances (allocated based on depreciation):
    • Lagos: N350,281
    • London: N374,719
    • Total Capital Allowance: N725,000
  3. Companies Income Tax Payable (30%):
    • Lagos: 30% of N21,124,879 = N6,337,464
    • London: 30% of N22,093,781 = N6,628,134
    • Total Tax: N12,965,598
  4. Double Taxation Relief:
    • Based on the lower of half the Nigerian rate (15%) or Commonwealth rate (19.28%).
    • Relief = 15% x N22,093,781 = N3,314,067
  5. Final Tax Liability:
    • Total Tax: N12,965,598
    • Less Double Taxation Relief: N3,314,067
    • Final Tax Due: N9,651,531