Appeal Court Reaffirms CITN’s Regulatory Role in Nigeria’s Tax Practice
By Omolabake Fasogbon
The Court of Appeal, Lagos Division has reaffirmed the Chartered Institute of Taxation of Nigeria (CITN) as the sole statutory authority empowered to regulate the practice of taxation in Nigeria.
In a judgment delivered on July 15, 2026, the appellate court dismissed the appeal filed by Chief Afolabi Igbaroola and others against the Federal Inland Revenue Service (now Nigeria Revenue Service), CITN and others. The appeal challenged the judgment of the Federal High Court, Lagos Division delivered on May 21, 2019.
The decision upholds an earlier May 21, 2019 ruling by the Federal High Court, Lagos Division, effectively sustaining the framework that mandates professional accreditation by CITN for tax practice in Nigeria.
Commenting on the judgment, Registrar and Chief Executive of CITN, Mrs. Afolake Oso, said the ruling reinforces the Institute’s statutory mandate under the CITN Act to regulate taxation practice in Nigeria.
According to her, the judgment follows previous court decisions, including the 2007 Lagos High Court ruling in CITN v. ICAN, which held that taxation is a profession separate and distinct from accountancy and that the CITN Act empowers the Institute to regulate tax practice in Nigeria.
Oso noted that in 2013, the Court of Appeal upheld that position in ICAN v. CITN, while the subsequent appeal to the Supreme Court was withdrawn in 2015.
She added that in 2019, Federal High Court equally held in the Igbaroola case that individuals seeking to practise as tax agents need obtain CITN membership in line with the provisions of the law.
CITN declared that latest court decision affirms the court’s position on the legal framework governing tax practice, including its findings on the Tax Administration (Self-Assessment) Regulations, 2011, where they were found to conflict with the CITN Act.
“The judicial history from 2007 to 2026 reflects repeated judicial pronouncements concerning CITN’s statutory authority to regulate the taxation profession in Nigeria,” Oso said.
