Since the phased liberalisation of her economy in the late 1980s/early 1990s, Nigeria’s government has been intensifying efforts to attract foreign direct investment (FDI). Notably in 1995, the Federal Government (FG) enacted the Nigerian Investment Promotion Commission Act1 which, amongst other legislation, focused on attracting and protecting foreign investment in Nigeria. In the same vein, the earlier Industrial Development (Income Tax Relief) Act2 provides income tax relief for ‘pioneer industries’ and ‘products’ vide maximum of five (5) year ‘pioneer status’ (PS) tax holidays.