Section 27

(1) The total profits of a company for any year of assessment, shall
ment of total
be the amount of its total assessable profits from all sources, including chargeable
profits of
gains computed in accordance with Part VIII of Chapter Two, less the amount
companies
of any loss ascertained in accordance with subsection (6), and capital allowance
First
in accordance with the provisions of Part I of the First Schedule to this Act.
Schedule
(2) The capital allowance to be deducted in accordance with the provisions
Nigeria Tax Act, 2025 2025 No. 7 A 413
of Part I of the First Schedule shall be the amount relating to the qualifying First
capital expenditure incurred in generating the assessable profits: Schedule
Provided that where value added tax is due under this Act but not charged
on an asset, or in the case of an imported item, where the applicable import
duty or levy was not paid, the relevant expenditure shall not be eligible as a
qualifying capital expenditure.
(3) Where the qualifying capital expenditure is in relation to an asset that
is only partly utilised in generating the assessable profits, the capital allowance
on such qualifying capital expenditure shall be prorated and only the portion
relating to the taxable income shall be allowed as a deduction.
(4) The capital allowance computed shall not be prorated where the
non-taxable income constitutes less than 10% of the total income of the
company.
(5) Notwithstanding the provisions of subsection (4), the portion of capital
allowance attributable to priority activities of a company that enjoys economic
development incentive under this Act shall be deducted only from the assessable
profits of the priority business:
Provided that –
(a) in no circumstances shall the aggregate loss deductions from the
assessable profits or income exceed the amount of that loss;
(b) loss can only be deducted from the trade or business in which the
loss was incurred ;
(c) the loss shall be deducted to the extent possible from the amount of
the assessable profits of the first year of assessment after that in which the
loss was incurred, and in subsequent years until the loss is fully recouped;
and
(d) the loss incurred during any year of assessment shall be computed, in
accordance with the basis period provided in sections 22 to 25 of this Act.
(6) Notwithstanding subsection (5) or any provision of this Act, any loss
incurred in any period from sales, disposal or any other transaction in digital
assets shall only be deductible in determining the profits from the business
relating to digital or virtual assets.
PART VII – ASCERTAINMENT OF TOTAL INCOME OF AN
INDIVIDUAL