Home » CITN Syllabus » The final stage of the CITN Professional Exams is called Professional Taxation 2 level. It is the most advanced part of training for people who want to become Chartered Tax Practitioners. This course tests how well candidates understand complex tax rules, plan taxes strategically, and apply tax laws in different situations. It is the last step in CITN’s professional training, where students are skilled in dealing with local and international tax systems.
Using the CITN Professional Taxation 2 syllabus, students study advanced tax principles, corporate tax planning, and international taxation in detail. They cover topics on complex corporate tax strategies, international tax agreements, transfer pricing, and the details of Value Added Tax (VAT) systems. This syllabus isn’t just about theory; it focuses on practical skills, enabling students to solve real-world tax problems, create detailed tax reports, and make smart decisions.
Passing the Professional Taxation 2 exam shows that a candidate is ready for senior roles in the tax field. It proves their expertise and ability to analyze tax issues allowing them to obtain the CITN professional taxation certificate.
There are four courses at the CITN Professional Taxation II Level, and they include:
The Chartered Institute of Taxation of Nigeria (CITN) offers a course on Tax, Audit, and Investigation, which aims to give you the skills and knowledge to understand tax laws, carry out audits, and perform tax investigations. This course will teach you about the audit of all the variables in the income statement, the balance sheet, and the cash flow statement identifying the tax audit risk issues and risk assessment.
To study for this course, you should use the CITN syllabus, which provides a clear outline of the important topics you need to learn. This includes tax compliance, audit processes, investigation techniques, and ethical issues in tax practice. By following the syllabus, you can systematically study each area using recommended books, case studies, practice questions, and other resources. This structured approach will help you understand the material well, pass your examination, and apply what you learn to real-world situations.
This course gives candidates the knowledge and skill to identify the risky areas in tax audit and investigation (such as financial misstatements, tax evasion, and tax avoidance schemes) and provide mechanisms to counter Tax Avoidance and Tax Evasion.
At the end of this course, candidates should be able to:
iii. Explain the process for planning tax audit and investigation iv. Describe the process for controlling and recording tax audits and investigation
vii. Describe risk-based audit approach viii. Explain the statutory powers of tax auditors and investigators
| Syllabus for CITN Professional Taxation II Level | ||
| Level | Professional Taxation II | |
| Course Name | Tax, Audit, and Investigation. | |
| S/N | Topic | Breakdown |
| 1 | INTRODUCTION TO AUDIT AND INVESTIGATION | i. Meaning and objective of auditing and investigation ii. Merits and demerits of auditing and investigation iii. Qualities of an auditor and investigator iv. Fundamental principles of auditing v. Concept of expectation gap in auditing vi. Differentiation between Tax Audit and Statutory Audit vii. Differentiation between the Internal Auditor, External Auditor and Tax Auditor |
| 2 | TAX AUDIT/INVESTIGATION PRINCIPLES | i. Definition, nature, and purpose of tax audit/investigation • An overview of the tax audit • Classification and types of audit, etc. ii. Rules and objectives of tax audit/investigation • Legal framework for tax audit • Tax audit fundamentals iii. Difference between a tax audit and a tax investigation • The issue of forensic audit, legal issues, and the role of the tax auditor iv. Reasons for tax audit and tax investigation • Factors for selecting taxpayers for tax audit/ investigation • Qualities of a good tax audit and tax investigation exercise v. Appointment of tax auditors vi. Duties, rights, and obligations of tax auditors vii. Taxpayers rights and obligation viii. Professional responsibilities • Competencies and ethics of audit staff • Tax auditor’s independence |
| 3 | PLANNING OF TAX AUDIT AND INVESTIGATION | i. Sources of taxpayers’ financial and business information ii. General consideration, nature of business, industry, business cycle and tax compliance history iii. Audit/Investigation staffing and logistics iv. Preparation of tax audit/investigation programmes • Audit management and control • Case selection and assignment • Audit planning and preparation • Basic tax audit tools and techniques – Use of mark-ups – Use of input/output ratios – Use of tax performance ratios – Other audit techniques |
| 4 | CONTROLLING AND RECORDING AN AUDIT/INVESTIGATION | i. Review of accounting system • Review of Receipts & Vouchers, the primary books of accounts, cash flow, etc. • The examination of the ledgers, control accounts and the trial balance • Tax examination of the income statements particularly salient variables e.g. sales, administrative expenses, closing stock, etc. • Tax examination of the balance sheet, particularly the current assets, current liabilities and the working capital, to check liquidity risk. ii. Allocation and supervision of work iii. Documentation of work done • Documentation • Report writing iv. Management of working papers v. Evidence of proper review, conclusion and action steps vi. Management of commencement and close-out meetings vii. Preparation of audit/investigation report viii. Decision making after tax audit/investigation • Audit/Investigation closure ix. Conflicts resolution and settlement of tax disputes |
| 5 | INTERVIEW TECHNIQUES | i. Preparation for interview ii. Managing the interview process • Managing eye contact • Reading facial expressions and body language iii. Documentation of minutes of meetings and interviews iv. Human relation aspects of field interview |
| 6 | AUDIT EVIDENCE, TECHNIQUES AND PROCEDURES | i. Nature of audit evidence ii. Relevance and reliability of audit evidence iii. Audit techniques, inspection, observation, enquiry • The elements of risk, fraud and error, • The application of forensic audit and substantive audit techniques. iv. Forensic accounting/audit techniques v. Independent confirmation vi. Computation and checks, sampling techniques vii. Reliance on the work of other auditors, including statutory auditors |
| 7 | RISK BASED AUDIT APPROACH | i. Understanding Risk Based Auditing ii. Focus of the risk-based audit iii. Steps of risk based audit • Determination of the threats (fraud and errors) confronting the organization • Identification of control procedures for preventing, detecting or correcting threats • Evaluation of control procedures – systems review and test of controls • Determination of impact of control weaknesses and degree of auditing required iv. The risk-based approach • Taxpayer and Industry Profiling • Identifying specific compliance risks e.g. Low stock values compared to turnover; International transfer pricing; Financing arrangements; Wrongly classifying capital expenditure as deductions; etc. v. Process of risk based audit approach • Understand the Business Environment • Develop a Three-year Audit Plan • Preliminary Risk Assessment • Secondary Risk Assessment • Formal Exit Meeting • Reporting and Communication |
| 8 | STATUTORY POWERS OF TAX AUDITORS AND INVESTIGATORS | i. Power to obtain information ii. Power to enter premises iii. Power to obtain third party confirmation from banks, etc iv. Power of search and seizure under investigation |
| 9 | TAX AUDIT PROCEDURES AND RISK ASSESSMENT | i. Tax audit procedures and risk investigations • Tax audit procedures on income ascertainment • Tax audit procedures on expenditure ascertainment • Tax audit procedures on VAT – Input and output tax including refunds • Tax audit procedures on import duties • Cost of Freight and Insurance (CIF) investigations • Risk in stock taking • Risk controls in sales department ii. Sampling risk and forensic investigations iii. Materiality concept and tax audit investigations iv. Computer Assisted Audit Techniques (CAAT) relating to income and expenditure |
The CITN certification course, International Taxation, provides students with the required knowledge of taxation law and policy from a comparative and international viewpoint. It covers principles of international tax law, tax policy, double tax treaties, transfer pricing rules, and thin capitalization.
Studying international taxation with the CITN syllabus helps you not only to pass your exam but also to understand how taxes work across countries. It covers topics like transfer pricing, double taxation treaties, and tax planning. This course prepares you to handle tax issues for multinational companies and individuals, whether you are aiming for a career in tax consulting, finance, or international business. It’s all about grasping how taxes impact global economic connections and staying ahead in a changing world.
At the end of this paper, the candidate should know and understand the following:
iii. Causes of international double taxation.
vii. Application of Nigerian transfer pricing regulation to related party transactions.
viii. Effect of Thin capitalization on income taxes
| Syllabus for CITN Professional Taxation II Level | ||
| Level | Professional Taxation II | |
| Course Name | International Taxation | |
| S/N | Topic | Breakdown |
| 1 | INTERNATIONAL TAX POLICY | i. Introduction to International taxation ii. Objectives of international tax rules iii. Taxation of inward and outward investments iv. Definition of Key terms • Active and passive income distinction • Portfolio investment • Double taxation • Source and residence tax jurisdiction • Controlled Foreign Companies (CFC) v.Taxation and public international law • History of international tax law • Jurisdiction to tax including limits to tax jurisdiction arising from public international law • Rules of public international law governing the assessment and collection of taxes; cross-border enforcement of tax debts • Introduction to international fiscal policy • International settlement of fiscal disputes. vi. International fiscal policy and income/profits taxation vii. Causes of international double taxation of income/profits • Conflicts of residence and source • Conflicting definitions of connecting factors • Other causes of international double taxation (including particular issues for using citizenship as a connecting factor for taxation viii. Methods of relief from international double taxation • Relief by credit – including indirect/underlying credit and tax-sparing credit • Relief by exemption – including participation exemption • Practical difficulties in applying for relief by credit and relief by exemption • Relief by exemption and relief by credit compared: capital import neutrality vs capital export neutrality • Other methods of relief from international double taxation – relief by deduction of foreign tax; relief by deferral ix. International fiscal policy and indirect taxation Causes of international double taxation of indirect taxes: origin and destination bases of taxation • Relief for international shipping and airlines • World Trade Organization (WTO), General agreement on tariffs and trade(GATT), General Agreement in Trade in services (GAT) and their relevance to taxation. x.International cooperation between tax administrations • International cooperation by bilateral agreement; analysis of model agreements on administrative cooperation • Multilateral cooperation between tax administrations • Regional developments on co-operation. |
| 2 | RESIDENCE | i. General principles of jurisdiction • in personam jurisdiction • in rem jurisdiction • general/unlimited jurisdiction on worldwide income/property • limited jurisdiction on locally-sited or property or local-source income. ii. Jurisdictional links for different taxes • Customs duties • Good and services taxes • Estate and gift taxes • income taxes iii. The concept of connecting factors • In persona connecting factors – Nationality – Residence – Domicile iv. Other in persona connecting factors – ordinary residence; habitual residence. • In rem connecting factors – Situs – Source v. Individual residence • State practice in determining the residence of individuals: – The 183-day rules – Regular visitor rule e.g. business visit, 90+ days per year – Definition of a day (24 hours or part of a day) – Facts and circumstances of an individual’s life e.g. availability of home, Centre of individual’s life. vi. Residence of corporations • State practice in determining the residence of corporations: – Place of incorporation – Place of central management and control – Place of seat – Place of head office – Place of principal activity vii. Residence of controlling shareholder(s). • State practice in determining the residence of other entities viii. Partnerships – place of effective management ix. Trusts – residence of trustees; place of effective management |
| 3 | DOUBLE TAX TREATY (DTT) | i. DTT definition ii. History of DTT • The League of Nations • The G20 and OECD • The UN Group of Experts iii. DTTs and domestic laws iv. Purpose of DTT • Avoidance of international double taxation • Prevention of fiscal evasion, mutual agreement procedures, exchange of information and assistance in the collection of taxes. v. Stages in DTT • Negotiating DTT • Giving effect of DTT in domestic laws • Commencement of DTT • Termination of DTT vi. DTT FORMAT • OECD Model and the Commentaries to the OECD Model • UN MTC • Specific states’ models: the US MTC; the Dutch MTC vii. INTERPRETATION OF DTT • General approach to interpretation • The importance of the Vienna Convention on the Law of Treaties. • The use of external aids for interpretation such as the status and use of the OECD Commentaries. • The application of OECD MTC • How interpretation issues are to be resolved by competent authority proceedings – OECD MTC. • Commentaries on the relevant articles based on the Base Erosion and Profit Shifting Project by OECD and the G20 viii. DTT PROVISIONS RELATING TO BUSINESSES • Business profits (with or without a permanent establishment) – Art 7 OECD MTC • Shipping and air transport profits – Art. 8 OECD MTC (in outline) • Associated enterprises – Art. 9 OECD MTC: status of Art. 9 and link to transfer pricing legislation ix. DTT PROVISIONS RELATING TO INDIVIDUALS • Employment income – Art. 15 OECD MTC • Pensions – Art. 18 OECD MTC x. DTT PROVISIONS RELATING TO INVESTMENT INCOME AND GAINS • Income from land – Art. 6 OECD MTC • Dividends – Art. 10 OECD MTC – • Interest – Art. 11 OECD MTC • Royalties – Art. 12 OECD MTC • Capital gains – Art. 13 OECD MTC xi. RELEVANCE OF THE “OTHER INCOME” ARTICLE – ART. 21 OECD MTC xii. LIMITATION OF BENEFIT PROVISIONS- BEPS ACTION 6 PROVISION OF TREATY ABUSE xiii. NIGERIAN DTT MODELS • Nigerian Tax Treaties and Reliefs • Typical clauses • Treaty relief by credit • Unilateral tax credit • Reforms and planning |
| 4 | CONCEPT OF PERMANENT ESTABLISHMENT (PE) | i. Application of domestic laws ii. The structure of the business profits provisions • Overview of Arts. 5, 7, 8 and 9 • Relationship with the dividends etc. Arts. – Art. 7(7); 10(4), 11(4); 12(3); and capital gains Article 13. iii. The permanent establishment concept • The concept of a PE – sufficient presence in a host state • The structure of Art. 5 – The fixed place of business PE: paras. (1) – (2); the construction site PE: para. (3); the exempt activities: para. (4); the dependent agent permanent establishment: paras. (5) – (6); associated companies: para. (7); “associated” and “unassociated” permanent establishments iv. The “fixed place of business” PE – The basic concept in Art. 5(1) • The requirement of a place of business • The requirement of being fixed. v. The illustrative list in para. (2) • What is the purpose of the illustrative list? vi. The building site PE • Is it a restriction on Art. 5(1)? – does it need to be equally fixed? • When does the period begin and end • Linked contracts • Use of sub-contractors. vii. The exclusionary list: para. (4) • Facilities or storage space • Are the separate items all preparatory and auxiliary • What does “preparatory and auxiliary” mean • Combination of activities – (4)(f) • Gathering information; representative offices. viii. The dependent agent PE – Dependent agent: para. (5) Definition and different concepts of agency – common law and civil law; common law: agent for an undisclosed principal; civil law courtiers and commissionaires générales. ix. Independent agents: para. (6) – Candidates should consider broker and general commission agent; other agents of an independent status (independent legally and economically) x. Associated companies – Candidates should also understand situations where subsidiaries would constitute a PE. xi. OECD BEPS final report on preventing the artificial avoidance of PE status (Action 7). |
| 5 | CONCEPT OF TRANSFER PRICING AND NIGERIAN TAXATION | i. Overview of the Nigerian Transfer Pricing Regulations ii. Definition of Key terms • Associate enterprise • Controlled transactions/ covered • Uncontrolled transaction • Independent enterprise • Arm’s length principle • Connected taxable person iii. Specific transactions iv. Comparability factors v. Transfer pricing analysis • Industry analysis • Company analysis • Functional analysis • Economic Analysis – Transfer pricing methods – Bench marking analysis vi. Other issues |
| 6 | EFFECTS OF OFFSHORE JUDICIAL DECISIONS | i. Judicial decisions on international tax matters • The interpretation of the concept of beneficial ownership • Resolving issues of dual residency for individuals and corporations • Meaning of connecting factors • Meaning of “liable to tax” and “subject to tax” • Other relevant judgments on the interpretation and application of DTT |
| 7 | THIN CAPITALIZATION AND NIGERIAN TAXATION | i. Definition ii. Measures of addressing thin capitalisation iii. Effects of thin capitalisation on taxes |
| 8 | INTERNATIONAL TAX AVOIDANCE AND NIGERIAN TAXATION | i. Tax evasion and avoidance ii. Tax avoidance and tax planning iii. General principles of domestic laws iv. Tax savings v. Decided cases |
The CITN Financial and Tax Analysis course equips you with comprehensive knowledge and practical skills in analyzing financial statements within the context of taxation. This specialized program from the Chartered Institute of Taxation of Nigeria (CITN) focuses on the crucial connection between financial reporting and taxation laws.
Following the CITN syllabus which covers key topics such as financial statement analysis, tax implications of financial decisions, strategies for tax planning, and compliance with regulatory requirements, you will gain a deep understanding of how financial data influences tax assessments and learn effective ways to navigate complex tax environments. The course prepares you for professional roles in taxation, accounting, and financial management by emphasizing practical applications and current tax regulations.
At the end of this course, candidates will be able to understand the following:
iii. The purpose of accounting analysis is to evaluate the degree to which a firm’s accounting is captured in business reality;
vii. To understand forecasting at the first and second stages of prospective analysis and valuation.
| Syllabus for CITN Professional Taxation II Level | ||
| Level | Professional Taxation II | |
| Course Name | Financial and Tax Analysis | |
| S/N | Topic | Breakdown |
| 1 | FRAMEWORK FOR BUSINESS ANALYSIS AND VALUATION USING FINANCIAL STATEMENTS | i. The role of Financial Reporting in Capital Markets ii. From Business Activities to Financial Statements iii. Influences of the Accounting System on Information Quality iv. Alternative forms of Communication with Investors v. Public versus Private Corporations |
| 2 | BUSINESS ANALYSIS AND VALUATION TOOLS | i. Industry Analysis ii. Applying Industry Analysis iii. Competitive Strategy Analysis iv. Corporate Strategy Analysis |
| 3 | ACCOUNTING ANALYSIS: THE BASICS | i. Factors Influencing Accounting Quality ii. Steps in Accounting Analysis iii. Recasting Financial Statements iv. Accounting Analysis Pitfalls v. Value of Accounting Data and Accounting Analysis |
| 4 | ACCOUNTING ANALYSIS: ACCOUNTING ADJUSTMENT | i. Recognition of Assets ii. Asset Distortions iii. Recognition of Liabilities iv. Liability Distortions v. Equity Distortions |
| 5 | FINANCIAL ANALYSIS | i. Ratio Analysis ii. Cash Flow Analysis iii. Trend Analysis iv. Common Size Analysis |
| 6 | STRATEGIC TAX MANAGEMENT AND PLANNING | i. Introduction • Definition of tax planning. • Tax planning and management strategies. • Taxation and present value analysis. • Basic principles of tax planning. • Factors affecting tax planning. ii. Tax strategies for new business • Organizational forms for business entities, corporate formation, partnership formation, single proprietor formation. Basic tax consequences of entity choice. • Sale or lease of property to controlled entities. • Other strategies for transferring property to controlled entities. iii. Employee compensation strategies • Proprietor compensation, employee compensation, fringe benefits. • Deferred compensation, equity-based compensation, employee stock plans/option. • Partnership interest as payment for services. iv. Taxation and business operating strategies • Profit measurements and reporting. • The entity’s accounting year, tax accounting methods. • Differences (permanent and temporary) between book profit and taxable profit. • Accounting for income taxes: deferred tax assets and liabilities, corporate tax payment requirements v. Tax incentive provisions: • Tax incentives and after-tax business value, criticisms of tax incentives; and • Restrictions on their benefits. vi. Tax implications of profit distributions – corporate, partnership and sole proprietorship. vii. Tax implications of Anti-Avoidance Schemes. viii. Taxation and Capital Marketing Activities. ix. Tax planning and management, using holding companies and group structures; x. Tax implications and tax management in mergers and acquisition of business entities. xi. Tax planning through the use of derivative instruments. xii. Tax considerations and tax planning in intellectual properties management |
The CITN Income Tax for Specialized Businesses and Processes introduces you to the peculiarities of specialized businesses and the specific tax rules that guide the imposition of income tax on the profits of companies involved in these businesses You will study sector-specific tax laws, compliance requirements, and strategic tax planning techniques.
To prepare effectively, follow the CITN syllabus closely. Understand the course structure, break down each topic, use the recommended resources, and practice with past exam papers. By sticking to the syllabus, you’ll cover all the necessary material and be well-prepared for examination in both the theoretical and practical parts of the course.
At the end of this paper, the candidate should have the knowledge and understanding of the following:
| Syllabus for CITN Professional Taxation II Level | ||
| Level | Professional Taxation II | |
| Course Name | Income Tax for Specialised Businesses and Processes | |
| S/N | Topic | Breakdown |
| 1 | TAXATION OF BANKS AND OTHER FINANCIAL INSTITUTIONS (BOFI) | i. Explain the concept of revenue recognition for BOFI and the various types of revenue viz interest income, commission, sale of financial instruments, financial intermediation etc. ii. Determine which of the streams of income would qualify as revenue and or other income under the relevant accounting standards – Specifically the International Financial Reporting Standard (IFRS 15). iii. Explain the accounting treatment of hedging transactions and discuss its income tax implications iv. Define and explain the various financing arrangements and loan relationships engaged in by BOFI including but not restricted to syndicated loans and sale and lease back arrangements v. Discuss the CIT exemption order for the exemption of short-term securities, bonds, Section 23(l) of the CITA etc. and their impact on the taxation of BOFI. vi. Differentiate between income earned in the ordinary course of business and income earned outside the ordinary course of business, i.e. sale of shares by a company and the sale of shares by a brokerage company. vii. Contemporary Issues such as the impact of Section 19 on Banks whose major source of income is exempted from income tax amongst others. |
| 2 | TAXATION OF INSURANCE COMPANIES | i. Distinguish between the types of insurance business types (General and Life) and identify their characteristics. ii. Identify and understand key terms which include: unexpired risks, claims, outgoings, gross premium interest, reinsurance expense, investment income, actuarial revaluation certificate, underwriting profits, premium, total premium, total profits and fees, etc. iii. Identify and understand what constitutes income for both types of businesses iv. Understand the requirement to separate the reporting and tax computation for both types of businesses v. Discuss the scope and charging provision in respect of income tax for both businesses. vi. Understand the limitation on certain allowable deductions and treatment of other allowable deductions and earned investment income for life businesses vii. Understand the provision on the restriction of loss carried forward. viii. Understand the definition of gross income for minimum tax purposes. ix. Explain and understand the provisions on the deduction of general reserve funds for re-insurance companies. x. Disclosure requirements for insurance companies that engage the services of an insurance agent, a loss adjuster, or an insurance broker. xi. Contemporary tax issues |
| 3 | TAXATION OF UNIT TRUSTS | i. Description and objectives of a unit trust scheme ii. Legal basis for the taxation of unit trusts – Section 17 of the CITA iii. Definition of key terms with particular reference trustees; unit holders; rights of unit holders; dividends; authorized unit trusts; etc. iv. Determination of the profits of a unit trust scheme and treatment of deductions suffered by unit trust schemes v. Applicability of provisions on dividends payment to profits accruing to trustees of unit trusts and tax-exemption (and otherwise) of dividends distributed by unit trusts vi. Withholding tax obligations for Unit Trust Schemes vii. Filing and payment requirements for unit trusts viii. Contemporary tax issues, such as tax transparency of the Unit trust system. |
| 4 | MINING OF SOLID MINERALS | i. Overview of the Mining Industry in Nigeria including a list of solid minerals available in Nigeria and their areas of concentration; types of mining licenses and process of obtaining a mining license. ii. Tax Incentives available to Companies involved in the Mining of Solid Minerals in Nigeria including, income tax reliefs, accelerated capital allowances, etc. iii. Treatment of decommissioning costs. iv. Contemporary tax issues |
| 5 | TAXATION OF AIR/SHIPPING/CABLE UNDERTAKING BUSINESS | i. Definition and examples of Air/Shipping Transport Business and Cable undertakings and their peculiarities. ii. Explanation of key terms as defined under Sections 14 and 15 of the CITA. iii. Explanation of the meaning of a Nigerian Company and a non-Nigerian Company iv. Procedure for determining profits derived from Nigeria and explanation of the concept of proportional profits v. Conditions for accepting proportional profits, calculation of adjusted profits, and adjusted depreciation ratios vi. Explanation of “fair percentage” as mentioned in the relevant provisions and related conditions (students should be aware of the applicable procedures for objections and appeals) vii. Minimum tax provision for these natures of businesses. viii. Provisions of the Double Tax Treaty on Air/Shipping Transport Business and Cable undertakings. ix. Contemporary tax issues such as the application of the Provisions of the Nigerian Information Technology Development Agency Act (NITDA) 2007 |
| 6 | TAXATION OF AGRICULTURAL BUSINESS | i. Definition of agricultural business ii. Legal Basis for the taxation of agricultural business iii. Computation of Capital Allowances (CA) computation for agricultural business and non-restriction of capital allowances including enhanced capital allowance for agro-allied plant and equipment. iv. Double tax treaty (DTT) provisions on immovable properties and their application to agriculture and forestry. v. Practical income tax computations for agricultural businesses |
| 7 | TAXATION OF OIL EXPLORATION AND PRODUCTION COMPANIES | i. Overview of the Oil and Gas Industry in Nigeria, delineating which activities fall under upstream, midstream, downstream, gas utilization, and Oil service sectors ii. Outline the basic roles of the Regulatory agencies in the oil and gas sectors, such as the NNPC, NAPIMS, NIPEX, DPR, CBN, FIRS, NCDMB iii. Understanding the applicable legislation for the various activities in the Oil and Gas Industry and the form of income tax payable. iv. Definition of Petroleum Operations based on the Petroleum Profits Tax Act (PPTA). v. Definition of Key Terms in the Upstream Sector vi. Description of the various fiscal/operating arrangements for upstream petroleum operations (i.e. Sole Risk Operation, Risk Service Contracts, Joint Ventures, Production Sharing Contracts, and Marginal Field Operators etc.) and whether participants will qualify as engaged in Petroleum operations as defined under the PPTA. vii. Understand what constitutes an accounting period for Petroleum Profit Tax (PPT) purposes and the basis of assessment. viii. Determine and understand the sources of income accruing to oil and gas (upstream) companies ix. Treatment of gas profits and analysis of gas production incentives. x. Definition and basis for the computation of adjusted profit, assessable profit, chargeable profit, and petroleum profit tax xi. Basis for treating expenses as tax-deductible or otherwise for PPT purposes including a summary of specific deductible and non-deductible expenses xii. Peculiarities of PPT computations vis-à-vis CIT computations – Treatment of Balancing Charge/Allowance, Tertiary Education Tax, NDDC Levy, Royalties. xiii. Description of qualifying capital expenditure for capital allowance purposes and compute capital allowance/petroleum investment allowance claimable by petroleum companies. xiv. Treatment of losses for E&P companies xv. Differing PPT and royalty rates and their bases xvi. Incentives available to companies that signed PSC agreement with the Federal government of Nigeria xvii. Offences and applicable penalties to petroleum companies xviii. Registration, reporting, and payment requirements for petroleum companies xix. Implications for the sale of license vs sale of shares, regulatory approval, and applicability of transaction taxes. xx. Contemporary tax issues which include: • Treatment of abandonment/decommissioning costs • Unitization agreements • Back-in-rights • Interest on intercompany loans • Community expenses • Gas banking • Joint filing of PPT returns • Dividends from gas business xxi. Review of case laws |
| 8 | MERGERS, ACQUISITIONS, TAKEOVERS AND RESTRUCTURING | i. Description of mergers (including the various types), takeovers, acquisitions, and restructuring ii. Legal Basis for the tax treatment for the various option iii. Understanding of the issues to consider before mergers, acquisitions, etc. (e.g. filing of returns, payment of outstanding tax liabilities, tax queries or audits, and availability of tax clearance certificates. iv. Possible tax incentives/planning options during mergers, acquisitions and takeovers v. Treatment of capital allowance and tax-written down value of assets after mergers, takeovers, acquisitions, and restructuring vi. Application of the relevant rules (i.e. Commencement, Change of accounting date and cessation rules) post mergers, takeovers, acquisitions, and restructuring |
| 9 | INDUSTRIAL DEVELOPMENT (PIONEER LEGISLATION) | i. Identify various pioneer industries and products, on the pioneer list ii. Enumerate and understand the tax incentives available to pioneer companies (tax exemption, treatment of loss incurred during pioneer period; treatment of asset acquired during the period, etc) iii. Explain the procedure for applying for and obtaining pioneer status and how a pioneer certificate can be amended iv. Understand the provisions relating to retrospective operations and the date of production certification v. Understand the conditions for Qualifying capital expenditure for a pioneer company vi. Circumstances for cancellation, information, and publication of pioneer certificate vii. Tax relief period and the conditions for extension of the period by the National council of Ministers viii. With copious examples, explain the application of the commencement and cessation provision to pre and post-pioneer businesses, together with the treatment of losses and capital allowance of the pioneer period ix. Applicable restrictions to pioneer companies x. Contemporary tax issues |
| 10 | EXPORT/FREE TRADE ZONE BUSINESS | i. Definition of Free Zones and list at least 10 examples in Nigeria ii. Legal framework for the operation of Free Zones in Nigeria iii. Administration of the Free Trade Zone iv. Procedures for registering companies in the Free Zone and relevant reporting requirements v. The fiscal benefits/incentives for operating in a Free Zone vi. Specific tax implications of operating in a Free Zone which may also include transaction taxes such as value Added Tax and Withholding tax (WHT). vii. Contemporary tax issues |
| Exemptions from the CITN Professional Examinations | ||
| S/N | QUALIFICATION | EXEMPTION (NEW) |
| 1 | TTS Graduates, (ATT)/ATS/ATSWA, OND (Accounting &Taxation) | All Foundation Papers |
| 2 | ICAN(ACA) | All Foundation Papers, All PT I papers & PT II papers except Income Tax for Specialized Businesses |
| 3 | ANAN(CNA) | All Foundation Papers, All PT I papers & PT II papers except Income Tax for Specialized Businesses |
| 4 | BL | All Foundation Papers, All PT I papers & PT II papers except Financial/Tax Analysis and Income Tax for Specialized Businesses |
| 5 | ACCA | All subjects at all levels except Business Laws, Income Tax for Specialized Businesses |
| 6 | CIOT | All subjects at all levels except Business Laws, Income Tax for Specialized Businesses |
| 7 | CITN TAX ACADEMY (CTA) | Subject by subject exemption |
| 8 | CIMA | All subjects at all levels except Business Laws, Income Tax for Specialized Businesses |
| 9 | ACIB | All Foundation Papers, Financial Reporting and Governance, Risk & Ethics in PT I |
| 10 | ACS/ACIS/ICSAN | All Foundation Papers, Financial Reporting, and Financial/Tax Analysis in PT II |
| 11 | MNIM | All Foundation Papers, Governance, Risk & Ethics, and Financial Reporting in PT I |
| 12 | LLB | All Foundation Papers, All PT 1 Papers |
| 13 | HND/Degree Taxation | All Foundation Papers, All Papers in PT 1 and International Tax, and Tax Audit & Investigation in PT II |
| 14 | HND/Degree (Accounting) | All Foundation Papers, All PT 1 Papers |
| 15 | HND/Degree Banking/Finance/Insurance | All Foundation Papers, All PT 1 Papers |
| 16 | Degree in Economics | All Foundation Papers, All PT 1 Papers |
| 17 | HND/Degree Bus. Admin/Public Admin/Bus. Management | All Foundation Papers, except Principles of Taxation, and Financial Reporting & Governance, Risk Ethics in PT 1 Paper |
| 18 | HND/Degree Maths/Statistics | Economics in Foundation and Financial Reporting in PT I |
| 19 | Other Degrees not stated here | Subject-by-subject exemption upon presentation of transcript |
| 20 | Masters in Management Sciences with Taxation Option/Taxation course in Transcript | All papers in Foundation, all papers in PT I, International Taxation and Financial/Tax Analysis in PT II |
| 21 | Master’s Degree in Management Sciences | All papers in Foundation, all papers in PT I |
| 22 | All other Masters’ Degree | Subject-by-subject exemptions upon presentation of transcript |
| 23 | PhD in Management Sciences with Taxation Option/Taxation course in Transcript | All papers in the foundation, all papers in PT I, and all papers in PT II except Income Tax for Specialized Businesses |
| 24 | PhD Degree in Management Sciences | All papers in the foundation, all papers in PT I, and all papers in PT II except TaxAudit & Investigation and Income Tax for Specialized Businesses |
| 25 | All other Doctoral Degrees in Management Sciences | All papers in the foundation, all papers in PT I, except Tax Audit & Investigation and Income Tax for Specialized Businesses |
| 26 | All other Doctoral Degrees | Subject-by-subject exemptions upon presentation of transcript |
| 27 | FIRS/JTB Fundamental Level | Principle of Taxation in Foundation |
| 28 | FIRS/JTB Preliminary Level | All Papers in Foundation, all papers in PT I, and International taxation in PT II |
| 29 | FIRS/JTB Final Level | All papers in the foundation, all papers in PT I, and all papers in PT II except Financial/Tax Analysis |
| 30 | All other Professional Certificates | Subject-by-subject exemptions upon presentation of certificate |
