As the popular quote reads, “…in this world nothing can be said to be certain, except death and
tax.1 This underscores not just the importance of tax, but the relative constancy – the inevitability.
Given that it is a major source of revenue, and in view of the dwindling fortunes prompted by the
pandemic, it is understandable that the government is ever more interested in this area and would
thrive to exact as much tax as much as it can. Only influenced by the man’s innate prudency, the
taxpayer would equally seek to avoid liability by all means. In recent times, there seems to be no
other interest-generating area within the Nigerian tax space or any subject that has pitched the two
interests against one another more than the Value Added Tax (VAT) implication of rents. An area
beclouded by conflicting decisions,2

the recent decision of the Tax Appeal Tribunal sitting in
Lagos, on September 10, 2020, represents a long sought clarification on this nascent aspect of
Nigeria’s tax jurisprudence.

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