Taxation of non-resident companies involved in shipping operations has never really been the most settled area in Nigeria’s fiscal jurisprudence because of the latitude afforded the tax man in deciding the rate of tax applicable; and in certain cases, profits deemed to have been derived from Nigeria.1 However, there was a certain level of certainty as regards the tax base of non-resident shipping companies (NRSCs) until the collection of tax by the Federal Inland Revenue Service (FIRS) on demurrage and other ancillary income from inward carriage was challengedinCMACGMDelMasav.FIRS(DelmasCase).2 Theargumentof the FIRS and upon which the Tax Appeal Tribunal (TAT) based its judgement, was that such ancillary income were liable to tax under section 9 CITA.
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