Section 191

(1) Where a relevant tax authority is of the opinion that a disposition Artificial
is not given effect to, or that a transaction which reduces or may reduce the transactions
amount of tax payable, is artificial or fictitious, it may disregard any such
disposition or transaction, or direct that such adjustments be made with re-
spect to liability to tax as it considers appropriate, to counteract the reduction
of liability to tax and issue an assessment or additional assessment accord-
ingly.
(2) The provisions relating to objections and appeals under Chapter Four
of the Nigeria Tax Administration Act, 2025 , shall apply to a direction made
under this section.
(3) For the purpose of this section –
(a) "disposition" includes any trust, grant, covenant, agreement or
arrangement; and
(b) a transaction between connected persons shall be deemed to be
artificial or fictitious if, in the opinion of the relevant tax authority, the
transaction has not been made at arm's length.