Nigeria’s tax authority in $1.6m battle with Air France

The Nigerian government has issued a tax liability for Air France totalling $1.6 million, despite a double taxation agreement (DTA) between Nigeria and France, the carrier says. According to court filings obtained by The Africa Report, Nigeria’s Federal Inland Revenue Service (FIRS) claimed company income tax (CIT) between 2015 and 2020 from the airline.

Air France argued that according to Article 8 of the Nigeria-France DTA, the airline as a tax resident of France is entitled, “on a reciprocal basis”, to be exempted from CIT in Nigeria for profits derived from operations in international traffic.

Nigeria and France have a bilateral air services agreement which allows airlines from both countries to operate flights on each other’s routes.