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32. Reconstruction investment allowance
(1) Any person who, without reasonable excuse, fails to comply with this section, shall be guilty of an offence and liable on conviction to a penalty not exceeding N100 plus the amount of tax lost by the granting of the investment allowance made in respect of the expenditure in question.
(2) For the purposes of subsection (1) of this section the minimum tax to be levied and paid shall‐
(a) if the turnover of the company is ₦500,000 or below and the company has been in business for at least four calendar years be‐
(i) 0.5 per cent of gross profit; or
(ii) 0.5 per cent of net assets; or
(iii) 0.25 per cent of paid‐up capital; or
(iv) 0.25 per cent of turnover of the company for the year,
whichever is higher; or
(b) if the turnover is higher than N500,000, be whatever is payable in paragraph (a) of this subsection plus such additional tax on the amount by which the turn‐over is in excess of ₦500,000 at a rate which shall be 50 per cent of the rate used in paragraph (a) (iv) of this subsection.
(3) In the case of an asset in respect of which an allowance has been granted before the commencement of this sub‐paragraph, an allowance shall be made in respect of the asset for the number of years which, if added to the number of years of assessment for which allowance has already been made, equals the number of years of assessment for which allowance is to be made under the provisions of sub‐paragraph (1) of this paragraph:
Provided that if an allowance has been made for a number of years which is equal to or more than the number of years specified under sub‐paragraph (1) of this paragraph, a single allowance shall be made for an amount which is N10 less than the residue of the qualifying expenditure for the year of assessment in which this sub‐paragraph takes effect.