Section 27(i) of the Companies Income Tax Act disallows “any expense of any description incurred outside Nigeria for and on behalf of any company except of a nature and to the extent that the Board (“FIRS”) may consider allowable”.
PwC argued on behalf of the Appellant and the TAT agreed that section 27(i) does not apply to an expense that is incurred for the business and benefits of a company by itself but rather applies to expenses incurred on behalf of another company. The FIRS countered by submitting that the section applies to expenses incurred for the company and expenses incurred for another company.
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