Re-appraising the rules for the taxation of income of companies engaged in ‘not-for-profit’ activities in Nigeria

The rules in s 23(1)(c) of Nigeria’s Companies Income Tax Act on the exemption of income of ‘charities’ from tax appear difficult to formulate with precision, and for which reason their application has been challenging. This article contends that s 23(1)(c) is indifferently drafted, that neither of the decisions in which this provision has been applied nor the explanatory circular issued by the revenue authority aids the understanding of the law on this point, and that urgent law reform is needed in this area of the law – and in charity law in general – in Nigeria.