Companies Income Tax Act (CITA) is the main legislation that governs the taxation of corporations in Nigeria. About one trillion Naira was generated from the tax imposed by the Act in 2013. The amount was equivalent to one fifth of Nigerian federal government budget for that year. The amount could be used by government to perform its duties of providing public services and infrastructures of which investment promotion is included. Investment is very vital to the economic growth of a nation. This is because it creates jobs, alleviates poverty, reduces unemployment and brings foreign capitals. Consequently, government needs to promote investment and advertise for the available investment opportunities in the country. However, there are many factors that are considered by prospective investors before deciding on where to invest their capitals. Corporate tax and the laws governing it are part of them. The main question that comes up here is whether the Nigerian corporate tax law has impact on investment promotion. In other words, what impact does the law have on investment promotion? Is the law effective in promoting investment in Nigeria? Is there any loophole in the present corporate tax law that discourages investment in Nigeria? Is Nigerian corporate tax incentive regime adequate in curtailing anti-investment attitude in Nigeria? Is there any measure capable in curbing anti-investment in Nigeria? This research entitled ?An Examination of the Impact of Nigerian Corporate Tax Law on Investment Promotion? is an answer to these questions. The main aim of this work is therefore to ascertain the impact of the Nigerian corporate tax law on investment promotion. Thus, it focuses on ascertaining the efficacy of as well as the imperfection in the present corporate tax law in the promotion of investment in Nigeria. Doctrinal method of data collection is adopted. Statutes, books, journal articles and many other documents are used. To ascertain the result of this work, structured interviews with some investors and other stakeholders are conducted. It has been found that the present corporate tax legislation is effective in promoting investment in Nigeria. Constant increase in the number of companies and the amount of investment in the country shows a positive impact of the law on investment promotion in Nigeria. However, the law is not absolutely perfect. It is plagued by several problems that have negative impact on the promotion of investment in country. These inter alia include the rate of corporate tax, multiple taxation and non-compliance with the corporate tax law. Others are penalties for violation of the law perpetrated by some dubious companies and mismanagement of fund generated from taxation. To enhance the effectiveness of the law in stimulating more investments domestically and attract more FDIs it is recommended that the rate should be reduced. Multiple taxation should be eliminated and tax avoiders and evaders should be severely punished. Finally provisions of corporate tax penal regime that encourage evasion or avoidance of tax which reduces the government revenue usable for investment promotion should be amended.

CHAPTER ONE: INTRODUCTION

1.1       Background of the Study
Taxation in general, occupies a significant position in the economy of the country. As one of the primary sources generating revenues for government, the significance of it cannot be overemphasized. For instance, the Federal Government (F.G.) generated 2.2 and 2.8 trillion Naira as tax revenue for year 2009 and 2010 respectively. In 2012 and 2013, the F.G. budget was about 4.7 and 4.92 trillion Naira respectively.  In 2012 alone, the  Federal Inland Revenue Service (FIRS) collected the sum of 5 trillion naira as tax. In 2013, the Federal Government generated the sum of 4.8 trillion Naira from taxation. About one trillion Naira came from corporate tax. This was equivalent to one fifth (1/5) of Nigerian Federal Government budget for that year.
Investment is equally vital to the economic growth of a nation. This is because investing in various sectors of economy provides employment opportunities, lead to a high returns and more income to the investor which subsequently increase the government revenue. Furthermore, Foreign Direct Investments (FDIs) particularly from multinational corporations bring foreign capital in the form of technical skills, entrepreneurship, technology and investment fund to boost economic activities in the country. This can raise the standard of living in Nigeria. In order to achieve this, government has to attract companies and individual investors to invest in the country. It has to ensure the availability of necessary factors that can make them to decide to invest in the country. It has to promote investment in the country. Thus, investment promotion is necessary for the economic development of a nation
Investment promotion is a set of activities used by governments to attract investors. The activities may inter alia include advertising, providing market information, organising investment seminars and participating in trade exhibition. It also includes identifying potential investors, matching them with local partners and providing them with pre- investment implementation and post investment services. It may also include grantingincentives andscreening and negotiating with foreign investors. Simply put, investment promotion is government effort to communicate to investors about investment climate so as to convince them to invest or reinvest in the country. Consequently, investment promotion may attract companies and make them to decide to invest in the country.
However, before a company will take a decision to invest in a particular area, it makes a feasibility study of the investment project. In other words, it has to determine on how, when, where and how much capital will be spent on the available opportunities for the investment. This is what is called investment decision. It is one of the engines of long- term economic growth. In making an investment decision, there are various factors that companies take into consideration. Corporate taxation is one of them. This is the motivation  for  ?An  Examination  of  the  Impacts  of  Nigerian  Corporate  Tax  Laws  on Investment Promotion.?

1.2       Statement of the Problem
Nigerian corporate tax is governed by the Companies Income Tax Amendment Act (CITAA). However the Act is plagued by several problems that impact on investment promotion in country. For instance, the Act also provides that there shall be levied and paid for each year of assessment in respect of the profit of every company, tax at the rate of thirty Kobo for every Naira. This rate is among the highest in the world. It may negatively affect the status of investment in Nigeria.More so, the Act provides-Where in any year of assessment, the ascertainment of total assessable profits from all sources of a company result in a loss, or where a company‘s ascertained total profits results in no tax payable, or to payable which is less than the minimum tax, there shall be levied and paid by the company the minimum tax prescribed.
It is clear from the above that the CITA provides for the payment of corporate tax even if the company fails to secure any gain or profit. In other words, companies are obliged to pay tax even in the event of incurring loss in their business. This is a serious problem  that may negatively impact on companies in general and their investment in particular. Furthermore, corporate multiple taxation is another problem that can also leave an unpleasant impact on investment promotion in Nigeria. For example, Section 62(1) of  the CITAA provides that the company paying dividend or making distribution shall deduct there from tax at the rate prescribed under subsection (2) of this section.  Thus,  the Act further provides thatthe rate at which tax is to be deducted under this section shall be 10 per cent.  However, section 15 of the Act   imposes the payment of tax at the rate  of 30 % prescribed in section 29 (1) on a dividend received and distributed by a company. The effect of this is that the company is paying tax at this instance at the rate of 40%. This is a double taxation which also impacts on investment promotion.
Additionally, Education Tax Act provides that education tax which is taxed at a rate of 2% shall be charged on the assessable profit of a company registered in Nigeria. Also National Information Technology Development Agency Act, imposed one percent of the total profits of a company in the name of information technology tax. This is a multiple taxation that may have negative impact on investment promotion
Avoiding and evasive attitude of many companies also have negative impact on investment promotion in Nigeria. From the estimated one million registered  companies at the Corporate Affairs Commission (CAC), Nigeria, it is believed that an estimated 50% of these companies do not pay company tax. This is a serious problem.  It  makes  the Government to lose billions of Naira annually from the taxation of corporate bodies. This can subsequently reduce the government revenue which is used for public services. Beside the non compliance by indigenous companies with the CITA, foreign companies are even smarter in corporate tax avoidance. To evade or avoid corporate tax is to  deprive government sufficient amount of money to be used for public services. This can subsequently render it to be incapacitated to provide adequate security, good roads and other social amenities utilised by the investors. This can seriously discourage investment in the country.
Another problem which is also connected with the impact of corporate tax laws on investment promotion in Nigeria is the complexity of the Nigerian tax system. Before an incentive is granted a company has to pass through various agencies for screening and scrutiny. Lack of proper co-ordination between the various government agencies responsible for administering, approving and granting of various incentives constitutes a great problem and impediment to the investment in Nigeria. This is because the problem makes the incentives very difficult and too expensive to be obtained. This is a problem that can serve as a hindrance for the promotion of investment in Nigeria. It is these problems that this dissertation addresses.

1.3       Research Questions
Looking at the above problems, the following questions may serve as a guide in the course of this research.
i.          What impact-if any- does Nigerian corporate tax law have on investment promotion?
ii.         Is Nigerian corporate tax law effective in promoting investment in Nigeria?
iii.        Is there any loophole in the present corporate tax law that discourages investment in Nigeria?
iv.        Is Nigerian corporate incentive tax regime adequate in curtailing anti investment in Nigeria?
v.         Is there any measure to be taken which is capable of curbing anti investment promotion in Nigeria?

1.4       Aim and Objectives
The main aim of this work is therefore to ascertain the impact of the Nigerian corporate tax law on investment promotion. It equally aims at realising the following objectives-
i.          To ascertain the efficacy of the Nigerian corporate tax law in the promotion of investment in Nigeria;
ii.         To ascertain the imperfections in the existing corporate tax law militating against the promotion of investment in Nigeria;
iii.        To examine the adequacy of the extant corporate tax penal regime in curbing the anti-investment promotion in Nigeria; ;
iv.        To update the knowledge contained in the written literatures existing in the field of this research; and
v.         To make recommendations capable of addressing the challenges revealed in the study.
The above could only be achieved by making a critical analysis and appraisal of the relevant provisions, as well as an extensive discussion of the problems identified, before final suggestion could be given. The hope is that this research will be a vital means and effective tool for simplifying the understanding of the laws governing corporate taxation and its impacts on investment promotion in Nigeria.

1.5       Justification of the Research
This research will be useful and beneficial to various stakeholders. This is because taxation in general and corporate taxation in particular is part of the curricular of tertiary institutions. Different aspects of corporate taxation are taught to various categories of students. For instance, students of law learn Revenue or tax laws; Students of Economics and business also touch some aspects of corporate taxation; and Finance and Accounting students are trained on tax accountancy; and students of public and business administration study management of corporate tax or tax administration. Consequently, this work can serve as a guide to the above categories of students at both the undergraduate and postgraduate levels.
The work also benefits the academic staff particularly the lecturers of law and taxation. This is because teachers need to constantly enhance their knowledge and update their data. This research work contains up to date information in the area of law and corporate taxation. It will therefore serve as a great assistance to them in order to impart a strong and viable knowledge on students in that area.
Since part of the duties of legal practitioners is to assess and evaluate individual cases so as to assist the court in clarifying the provision of law, the research can subsequently assist them. Sometimes tax administrators get confuse in comprehending and applying the principles and rules of taxation. They get lost when they come across some legal terms and phrases or provisos contained in corporate tax laws. This dissertation will equip them with some skills that they may need in their struggle with taxpayers that employ expert on taxation in order to avoid corporate tax that may have negative implications on revenue generation and investment promotion in the country.
The principal obligation of the courts is to interpret laws and apply them to the relevant case presented to them. Any decision made by superior courts of records is considered to have the force of law and sanction similar to the law made by the legislature. Sometimes judges are confronted with critical issues in determining conflicts assessment, collection or accounting of corporate tax. This dissertation may also render assistance to them.
It is also proper to state that Nigerian Constitution confers power on the National Assembly as well as the State House of Assembly to make laws for the peace, order and good governance of the Federation and states respectively. They can equally make laws on taxation of which corporate taxation is included. Consequently the Legislators may utilise this work to enhance their knowledge for correct understanding and proper law making on corporate taxation.

1.6       Significance of the Research
It must be observed that revenue generated from taxation in general and corporate taxation in particular, sustains the economic and social needs of the nation. In fact, revenue serves multifarious ends, some of which have political, economic or social bearings. In a nutshell, the essence of taxation is to raise revenue for government expenditure or finance government projects, control consumer demand, encourage investment and savings, fight economic depression, inflation and deflation, guarantee equitable distribution of income and wealth, control the general trend of the national economy, and ensure a proper allocation of national resources.
Like any other type of taxation, corporate taxation essentially aims at raising sufficient revenue for the Government. This is to enable the government to make the provision of services like defense and security of the nation; maintaining law and order; and providing health services and education to the people of the nation. Revenue from this tax could also be used on capital projects, creating social and economic infrastructures, which improves the life of people and enable the economy of the country to grow. In other words, corporate tax can also be used in shaping the economic growth and development of the nation. In addition, corporate tax has become an instrument for wealth re- distribution between the wealthy and industrialized economies represented by the Multi- National Companies (MNCs), and the poor and emerging economies from where the resources are extracted. The MNCs own the technology, expertise and capital needed to develop the industries. They repatriate their earnings and often very huge profit to their wealthy countries. To tax the companies is a way of achieving the objective of wealth re- distribution, among these nations. Corporate tax can also be utilized to guide the behaviours of economic agents. The significance of this research lies in improving the regime of corporate tax system in Nigeria.

1.7       Scope and Limitations of the Research
Geographically, the research covers only Nigeria. However, references are made to other countries where it becomes necessary in order to buttress some certain points in this research. Unlike some countries that advocate consumption as the basis of taxation, Nigeria based its tax on income. Consequently, this contains the historical background of income tax in the country. Evolution and development of the law governing the corporate taxation is also incorporated into this work.
Despite the fact that corporate tax may cover all registered and incorporated companies including the oil producing companies, nevertheless in Nigeria the taxation of any company engaged in petroleum operation is governed by a legislation different from the one governing the taxation of other companies. All registered and incorporated companies are presently taxed under the Companies Income Tax (Amendment) Act of 2007, while the companies operating in the oil downstream sub sector are taxed under the Petroleum Profit Tax Act (PPTA), This is because of the peculiarities of the companies engaged in petroleum operations. The focus of this work is on the former.
It is pertinent to understand that apart from the 30% tax rate imposed by the CITA on the profit of a company, Capital Gain Tax Act (CGTA) and Value Added Tax (VAT) Act of 2004 also affect the corporate bodies. Under the CGTA 10% levy is imposed on disposal of company‘s assets and 5% is the tax rate levied by VAT Act for the goods produced by the company. Consequently, the above Acts might be touched where it is deemed necessary. Another tax law, which is equally connected to the corporate taxation in Nigeria and may be useful to the topic of this research work, is the Education Tax Act (ETA) . It imposed 2% on the assessable profit of any company registered in Nigeria.  The rationale behind it is to fund research in the educational sector of the country. On  this ground, the research can make contact with ETA. Personal Income Tax Act (PITA) also imposed a tax on the income of the individual employees of companies. The tax is charged based on Pay as You Earn (PAYE) on the rate specified under Schedule 6 of the PITA. Subsequently, some provisions from the PITA might be mentioned. In fact, some provisionsof the CITA could not be properly understood unless when it is read along side with some provisions of the Companies and Allied Matters Act [CAMA]. For this  reason, recourse may be had to the Act . Federal Inland Revenue Service (FIRS) Establishment Act of 2007 must also be used for the purpose of this work.
It is important to note that one of the limitations in this work is the inability to cover all companies that are liable to tax in Nigeria for the purpose of obtaining information particularly empirical data. This is because of the financial constraint that does not allow to travel and investigate the reports of all companies in Nigeria or to interview any resource person that can make a relevant contribution to the work. Further the work has also hampered by serious lack of readily available statistical data on companies and different aspect of their activities connected to the taxation and investment in Nigeria. Another limitation is the skeptical attitude of some individuals assumed to be in possession of certain facts relevant to the research. They withhold or distort the particulars on the ground that spread of such information can serve as a threat to their trade or business and office or their personality.

1.8       Methodology of the Research
As the result of the research limitations the work issolely based on doctrinaland priori research method. In other words, the research would be embedded on the visualized and conceptual method. Basically, the work relies on both the primary and  secondary  sources of data. For primary sources of data legal statutes such as Companies  Income Tax Acts from the principal Act to the recently amended Act of 2007 would be used. Other tax laws like Capital Gain Tax Act (CGTA), Education Trust Act (ETA), Personal Income Tax Act (PITA) and Value Added Tax Act that have link with the research are utilized. Constitutions of the Federal Republic of Nigeria of 1960, 1963, 1979 and 1999 may also be cited. Companies and Allied Matters Act (CAMA) and Nigerian Investment Promotion Commission Act (NIPC) are also used in the course of this research. Nigerian and foreign cases are also cited in order to explain or support any point deemed necessary.
The secondary sources entail the usage of text books written by scholars and legal sages. This is because of their significant role in providing useful information on the topic of the research. Articles in the journals related to the research topic are similarly utilised. Newspapers contains issues relevant to the work may also be considered. Reports and conference papers on the topic or any other topic related to it may also be of great benefit to this thesis. The work also contains information from dictionaries, encyclopedias and thesauri. Materials available in the Internet websites of the Federal Inland Revenue Service (FIRS), Corporate Affairs Commission (CAC), Nigerian Investment Promotion Commission (NIPC) and other corporate bodies relevant to this workare equally used. This is to update the relevant information contained in this work.

1.9       Literature Review
The legal framework for corporate taxation is very vital and crucial to the economy of the nation. However, materials related to this topic are scattered. Issues related to it are only discussed in some few books. Consequently data connected to the work could only be obtained from different books on taxation and other relevant sources of information.
For example Ola C.S. made a great contribution with some issues related to the topic of this research. This is because he discussed the issue of corporate taxation in Nigeria. In his book entitled ?Income Tax Law for Corporate and Unincorporated Bodies in Nigeria‘
, he dealt with the assessment of companies and statutory corporations as well as the issues of pioneer companies and the excess profit tax. He also treated the issues of administration of the CITA and the profits chargeable to tax in addition to those exempted from taxation. Treatment of undistributed income as distributed, treatment of trades or business sold or transferred and treatment of artificial disposition were all incorporated in the book.  Furthermore, he also discussed the issues of relief, incentives for agricultural production, capital allowance, reconstruction investment allowances, allowable deductions and disallowable expenses. Principles on which assessment could be made on turnover of a company were also considered. Additionally, the author dwelt on the issues of Shipping companies, Air Transport companies, Pioneer companies and insurance and life assurance companies. The issues of taxation of profit on Nigerian statutory corporations as well as the taxation of interest on loan advance granted by a foreign company to its subsidiary Nigerian company were all spelt out in the book. Despite the fact that the author has touched different issues on corporate tax law, nevertheless the efficacy of the law in promoting investment in Nigeria has not been considered. This is the gap that this work covers.
In the book titled ?Nigerian Income Tax and Practice,‘ the same author - in addition to some issues mentioned above - equally, discussed some important matters related to the topic. These include the issue of taxation of banks profit, and the process for ascertainment of assessable profits. He also dealt with the issues of objection, appeals  and the revision of assessment in case of objection. Finally, he discussed the issues of offences and penalties under the Nigerian corporate tax regime. However, the book did not examine the adequacy of the corporate penal regime in curbing anti investment promotion in Nigeria. This is another blank space left by the author. This work seeks to fill the space.
Another book written by Ola which is also connected to the topic of this research is ?A Guide to Accountancy and Taxation Law for Business and Government? . Therein he discussed the issue of limited liability companies and the terms used in their published accounts. Despite the fact that the author discussed some positive impacts as incentive provided under the Nigerian corporate tax regime, nevertheless, critical look at his work, reveals that no consideration is given to the impact of corporate tax on investment promotion in Nigeria. This omission is sought to be addressed by this thesis.
Professor  Ayua  in  his  book  entitled  the  ?Nigerian  Tax  Laws?  ,  devoted  chapter  ten  to taxation of companies‘ profits. He therefore, discussed the categories of company for tax purpose. Under the CITA companies are divided into Nigerian and foreign ones. He equally treated the taxation of special companies. These include the shipping and Air Transport companies, cable and wireless companies and insurance companies.  The author also examined taxable income under the CITA. In line with it, he further made a clarification in respect of the income liable to tax under the Act. Trading profit and investment income were all discussed. Pioneer companies relief, computation of total profits, basis of assessment, and change of accounting date, commencement, cessation and sale of a trade or business are also among the issues treated by the author. Other issues also discussed include the rule for calculating a company‘s profits, deduction allowed and deduction not allowed, deductible donations, waiver or refund of liability or expenses, treatment of losses, capital allowance and the issue of levy on dormant companies. In addition, he treated the taxation of dividend to provide a complete picture of Nigerian companies‘ income tax. Ayua made mention of different kinds of deductions and allowances provided under the CITA. Definitely some of the allowances have linkage to the promotion of investment in Nigeria. Consequently, this work seeks to fill this gap by discussing the impacts of those provisions on investment promotion.
Oni, I.O. is also among the authors that have written a book on taxation of companies. In his book titled ?Nigerian Companies Income Tax: Law and Practice,? he dwelt on several matters on corporate taxation. These inter alia include-administration of companies income tax, tax incentives and relief, tax assessment, appeal procedure, offences and penalties and related taxes and levies to companies income tax. However, the book did not discuss the issue of the impact of corporate tax administration and incentives on investment promotion. This is the gap that this thesis tries to cover.
ICAN, also prepared –on line- a significant material that treated several issues on taxation. These inter alia included- the nature of companies income tax, ascrtainment of assessable and total profit capital allowances, coputation of companies incometaxation of special companies and returns, assessment and collection procedures. The material did not pay any attention to the issue of the impact of the tax law provided for the above issues on investment promotion. This is basis of this work.
Another material which is also relevant to the topic of this research is the text book on Revenue Law written by Andrian Shipwright and Elizabeth Keeling. In the book, the authors lucidly explained the issue of companies and United Kingdom (UK) tax. It is apparent that the authors discussed the issue of corporate taxation in the United Kingdom alone. They didn‘t touch anything on Nigerian corporate taxation let alone its impacts on investment promotion.
Professor  Bucke    contribution  is  very  useful.    In  his  book  entitled  ?Federal  Income Taxation of Corporations and Stockholders? he discussed the issue of corporate double tax. He therein stated some negative implications of it. He further treats the issue of corporation as taxable entity and the issue of incorporation. Other issues treated by him are non-liquidating distributions, redemptions, stock dividends,complete liquidations, collapsible corporations, taxable acquisitions, reorganizations, corporate divisions, carryover of corporate attributes and integration. Despite the significant contribution to the taxation of corporations, nevertheless he did not extensively discuss the impacts and implications of those tax laws on investment promotion. Furthermore, the book was written based on the provision of the United States Internal Revenue Code. It is therefore devoid of making any reference to the impacts of Nigerian corporate tax laws on investment promotion.
Dicker is another author that dealt with some issues of corporate taxation. In his book entitled ?Taxation of UK Corporate investment in the United States of America (USA)?, he discussed the issues of US taxation of profit, UK general principles and form of operation. Other issues explained by the author include the structuring and financing, acquisitions, intra group transactions, reorganisations and disposals. Although the book is a significant step in understanding some issues on corporate taxation, however it contains nothing in relation to the Nigerian corporate tax law let alone its impacts on investment promotion in Nigeria. This is because the book is foreign and was not written for the purpose of exploring the impacts of Nigerian corporate tax laws on investment promotion.
Aremu, discussed some conceptual issues in Foreign Direct Investment (FDI) and Transnational Corporations (TNC). He equally explicated the issue of policy objectives and performance of FDI in Nigeria. Finally the basis for negotiating FDI with TNCs and the issues and processes in negotiation were also expounded. It is obvious that the work  is not on the impacts of Nigerian corporate tax law even though that it contains the issues of FDI in Nigeria. More so, it is not general on investment in Nigeria. It is only limited  to the FDI. These issues are addressed in this work.
Adesola‘s  book  entitled  ?Income  Tax  Law  and  Administration  in  Nigeria?   discussed various issues related to the administration of tax in Nigeria of which corporate tax management is included. Thus the book contains the issue of returns as well as tax assessment and recovery. Other issues included in the book are: Ascertainment  of income or profit from trade; Ascertainment of assessable income and profits; Ascertainment of total and chargeable income; Capital allowances and treatment of losses. This research attempts to address the problems affecting the promotion of investment as the result of the laws governing the administration of corporate taxation in Nigeria.
Jugu is another scholar that made a significant contribution in this field. In his book entitled ?Principle of Taxation?  he made mention of many issues related to the topic of this research. Taxation of Banks and insurance companies are inter alia, discussed by the author. Issues of construction companies, shipping companies and airline companies  were specifically treated. The issue of double taxation relief was equally considered. However the impacts of the above corporate tax provisions on investment promotion has not been addressed. This is what this work tries to do.
Auru,  O.H.  ,  wrote  a  book  entitled  ?Principles  and  Practice  of  Taxation?.   The  book discussed some issues related to corporate taxation. For instance, the issue of company income tax, the position of a company, registration of a company, income chargeable to tax, profit exempted from company income tax and determination of profit are all discussed in the book. However, neither the impact of provisions of corporate tax on investment promotion nor imperfection of the law militating against the promotion of investment in Nigeria is discussed in the book. This is part of what this work examines.
Professor Abdurrazaq, also authored a book useful to topic of this research. The book entitled Nigerian Revenue Law is one of the recent literatures that discussed the issue of taxation of companies and corporate bodies in Nigeria. In the book, the author concedes to the fact that the work is not comprehensive enough. It only discussed the fundamental principles of revenue law needed by the tax law practitioners. The book did not identify the impact of those principles on investment promotion in Nigeria. This is what this research proposes to do.
The same author made another contribution useful to this work. In his journal article entitled ?Legal Mechanism for Corporate Tax Relief? he brushed on different issues connected to this work. This inter alia, include- taxation of companies and its administration, categories of companies and the rate of tax, taxation of dividends received by companies and profits exempted from income tax. Others are capital allowance, pioneer status, double taxation relief, compliance issues and tax planning, avoidance and evasion. Despite the fact that the author has discussed some corporate tax incentives, nevertheless, their impact on investment promotion has not been treated. This work intends to fill this gap.
Ojo, S. also made a contribution in relation to the topic of this research. In his book entitled  ?Fundamental  Principles  of  Nigerian  Taxation?  he  discussed  the  issues pioneer legislation. The book did not touch the issue of the impact of the provisions of those tax legislations on investment promotion.
Soyode, and Kajola also made a contribution to the topic of this work. In their book entitled  ?Taxation  Principles  and  Practice  in  Nigeria?  they  discussed  the  issue  of  tax administration under which they made a vivid explanation on relevant tax authorities. Therefore they discussed about the Federal Board of Inland Revenue(FBIR), Federal Inlad Revenue Service (FIRS), State Board of Internal Revenue (SBIR), Local Government Revenue Committee (LGRC) and Joint Tax Board (JTB). They also elucidate on different types of assessment and collection of taxes. They also discussed on companies income tax and pioneer companies status. The issue of double taxation relief was also discussed in the book. However critical look at the book reveals that the authors did not point out the impact of the above issues on investment promotion
Ariwodola, J.A. discussed several issues related to taxation. Nigerian tax system is among  the  main  issues  treated  in  his  book  entitled  ?Personal  Taxation  in  Nigeria?. Furthermore, issues of withholding tax, capital allowances, assessment, appeal and backduty, clearance certificate  and double taxation relief  are all discussed.  However, the book is on personal income taxation. Therefore, it is devoid of discussing issuesof corporate taxation let alone their impact on investment promotion in Nigeria.
Orojo,O.          wrote a book connected to the topic of this research. In  his  book entitled
?Company  Income  Tax  in  Nigeria?  he  discussed  various  issues  on  corporate  taxation. However, the issue of the impact of corporate tax law has not been given proper attention. Additionally, his work was based on the Companies Income Tax Act, 1961.
The Act was amended and consolidated in 1990. The outcome of the work is no longer current. Furthermore, corporate tax laws in Nigeria have undergone several amendment and reforms. The recent one is that of 2007. This work is based on current provisions of corporate tax laws in Nigeria.
Kanyip, B.B. is another scholar that made a contribution to the of knowledge on the issue  of  taxation.    In  his  article  entitled  ?Taxation  Issues  in  Foreign  Investment?,  he discussed some important issues related to the topic of this research. These inter alia include- tax incentive regime, classical method of taxing companies and its implications for business, and investor friendly judicial disposition. However taxation is a very vast field. Issues related to  it are infinite and inexhaustible.  The author did not dwell on  issue of the impact of Nigerian corporate tax law on investment promotion. This is the gap that this work fills in.
Abata M.A. wrote an article which may be useful to this research work. In his journal article  entitled  the  ?Impact  of  Tax  Revenue  on  Nigerian  Economy?  he  discussed  the issues of tax avoidance, tax evasion and tax administration. He also made mention of the contribution made by corporate tax revenue from 2002 - 2007 to national Gross Domestic Product (GDP). In 2002 the contribution was 5.1%, 4.5% in 2003, 3.3% in 2004,2.9% in
2005, 3.4% in 2006 and 4.8% in 2007. He attributed  the decline in percentage of  revenue contribution to the problems of tax evasion / avoidance in which corporate bodies are part of the perpetrators. Corruption and poor tax administration are also part of the cause. In spite of the importance of the article however there is nostatement on the impacts of the revenue generated from corporate tax and the law governing it on investment promotion.
Bakre, M.O. also discussed important issues connected to the topic of this research. In his article entitled ?Tax Avoidance, Capital Flight and Poverty in Nigeria?, he analyzed various means employed by multinational corporations in avoiding or evading the payment of tax. However he did not dwell on the impact of the law governing the taxation of those companies on investment promotion.
The main report of the study group on Nigerian tax system dwelt on several issues connected to the topic of the field of this work. The report was published by the FIRS and  entitled  ?Nigerian  Tax  Reform  in  2003  and  beyond?.  It  contained  reports  and recommendation of the Study Group on various issues of taxation. Tax incentives and disincentive as well as companies income tax issues are among the issues discussed. Specifically, the Report did not ascertain whether the present Nigerian corporate tax incentive regime has negative or positive impact on investment promotion.
The Education Committee of the Chartered Institute of Taxation of Nigeria (CITN), has also compiled and published a series of seminar papers presented at different occasions and programs organised by the CITN. In its 2009 series, the committee published papers of different topics connected to this work. This inter alia includes- The Implication of Multiple Taxation on the Viability of business; Tax Incentives as a Tool for Tax Compliance; tax Reform in Nigeria and Effective Tax Planning Strategies. A perusal at the papers shows that there is no any topic on the impact of Nigerian corporate tax law on investment promotion.
Babatunde and Shakirat also made a contribution with what is related to the topic of this research. In their journal article, the wrote on impact of tax incentives on Foreign Direct Investment (FDI) in oil and gas in Nigeria. They consequently discussed the determinant factors of FDIs and analyses whether or not some selected factors such tax incentives, availability of natural resources, macro-economic stability, market size, openness trade, infrastructural development and political risk have impact on FDI in oil and gas sector. Their finding was that only tax incentives and availability of natural resources that have significant impacts on FDI. Therefore they recommended that a particular attention should be given to institute new regulations to encourage the types of FDI needed to support the economic objectives of vision 20-20 such as provision of infrastructure especially electricity. This is to improve economic growth and the inflow of FDI in Nigeria. However this article left a vacuum in bringing out whether  the  current corporate incentive regime has positive or negative bearing on investment promotion in Nigeria. Furthermore, no criteria was set up for determining the impact of the tax provision on investment. This is what the research seeks to discourse. .
Ali, H.L .also has an article which is also related to this work. The article entitled ? A Case For The Reform And Harmonization of Companies Income Tax Legislation in Nigeria? discussed the issue of legislative authority on tax in Nigeria and pointed out that the power to impose or legislate on tax matters in Nigeria is vested in the National Assembly. He further looked at salient rules of good tax system and legislation, the exempt income from company taxation, companies tax rate, deductible expenses and the taxation of foreign companies. He equally treated the issue of tax administration under the CITA, the treatment of dividend paid by a Nigerian company and the basis of computation of profits of a company on cessation of trade or business. But the article did not address the whether those legislations have positive or negative impact on promotion of investment in Nigeria. The work will therefore look at this point.
Adeoye, O.J. wrote on significance of taxation in a nation. In the article , he discussed  the meaning of the term tax , difference between tax and charge or fee and brief history  of taxation in Nigeria. He also touched the issue of principles of good tax system. In spite of the significance of the article, the issue of the impact of corporate tax law has not been discussed.
Atilola, B. also wrote on the Reflection on the constitutionality of the Newly Constituted Tax Appeal Tribunal (TAT ). In the work, he dealt with the composition , powers, jurisdiction and constitutionality of the TAT. He explained the issue of TAT and their jurisdiction over the Taxes and Levies (Approved List for Collection )Act. TAT is very important for dispute resolution particularly those related to corporate tax. However the author did not show the relationship between the TAT and investment promotion in the country.
Somorin, O.A. wrote something connected to the topic of this dissertation. In her article entitled the Origin and status of Revenue Boards in Nigeria, she extensively discussed the revenue authorities as well as the introduction of income tax in Nigeria. The article did not address the issue of the impact of corporate tax administration on investment promotion in Nigeria. Thus, this thesis is meant to inter alia address such issues.
Ochei, B,B, also wrote on Tax Administration in Retrospect. In his work he examined  the landmark changes in Nigerian taxation since the colonial times. He prescribed the enthronement and observance of the provision of fiscal statutes in tax collection. The
author did not look at the impact of the provisions ofNigerian corporate tax administration on promotion of investment. Additionally, no any criteria was set to determine the impact of corporate tax administration in Nigeria. This is also considered in this thesis.
Kwaghkehe, I. and Samuel, S.T. wrote another article which is also connected to the topic of this research.  The title of their article is ?Global Perspectives in Tax Evasion and Avoidance: The Legal Quagmire in Nigeria?. The article contained a brief discuss on the concept of corporate tax avoidance / evasion, mechanism for corporate tax avoidance/evasion, the place of tax havens in promoting tax avoidance / evasion in Nigeria and the means for curbing tax voidance/evasion in Nigeria. But the article did  not dwell on the adequacy of the corporate tax penal regime in curbing anti investment promotion in Nigeria. This aspect is equally discussed in this work.
Generally, the above examination can lead to a conclusion that the issue of the impacts of Nigerian corporate tax laws on investment promotion have not been given adequate attention. Legal luminaries that have written on corporate tax law did not specifically or extensively discuss the issue. In other words, even if it happened that those legal experts highlighted an effect or impact of a specific tax legislation connected to investment promotion, they only discuss it at a peripheral level. Furthermore, the books did not pinpoint some loopholes existing in the provisions governing the corporate taxation. In addition  to  this,  some  of  the  books  such  as  ?Income  Tax  Law  for  Corporate  and Unincorporated Bodies in Nigeria, A Guide to Accountancy and Taxation Law for Business and Government and Income Tax Law and Administration in Nigeria?, were written in 80s and 90s. They are consequently devoid of discussing many contemporary
issues related to corporate taxation particularly the impact of the law governing the taxation of companies and corporations on investment promotion in Nigeria. Consequently, there is a need for a research specifically on this topic particularly when importance and significance of the impacts of‘ corporate tax laws in relation to the revenue generation is considered.

1.10     Organizational Layout
This work entitled ?An Examination of the Impacts of Nigerian Corporate Tax Laws on Investment Promotion? is an attempt to explore the legal effects of corporate taxation on investment promotion in Nigeria. For the purpose of attaining the aims of the research, the work is segmented into six chapters under some headlines related to the research topic. To simplify the work, each chapter is divided into sub-headings.
Chapter one of this works begins with general introduction to the research work.  It begins by a brief introduction of the laws governing the corporate tax in Nigeria. Importance of taxation in general and corporate taxation in particular is succinctly highlighted. It equally scans some problems connected to the impacts of Nigerian corporate tax laws on investment promotion. In addition, aims and objectives of the research as well as doctrinal or priori research method employed in the work are clearly spelled out. Moreover, geographical, historical and legal scopes of the research are all enclosed in the chapter. In order to justify the cause for this undertaking, significance of the research and those whom the research is going to benefit are also included. Besides, the chapter also states the significance of the research specifically the corporate tax laws and its impacts on investment promotion in Nigeria. The chapter ends with the organisational layout that briefly states the content of the work in general.
The second chapter is on conceptual clarification and background context for corporate tax law on investment promotion.  It is tagged as ?Analysis of the Concept, Development and Legal Foundation for Corporate Taxation in Nigeria?. It thereforeanalyses some  basic concept, legal foundation and development for corporate taxation in Nigeria. It also discusses the issue of corporate bodies liable to pay the tax. These include the Nigerian and foreign companies, special companies and representatives of the companies liable to pay the tax. Furthermore corporate income chargeable to tax is also explored. Subsequently trading profits and investment receipt are thoroughly discussed. Other issues treated under the chapter include the rate of corporate tax and corporate multiple taxation.
Chapter three handles the issue of the impact of corporate tax administration. It  explicates the historical background of the administration of corporate tax in Nigeria.  The structure and powers of the Federal Inland Revenue Service in relation to corporate tax is explored. Functions of the FIRS in relation to corporate taxation are equally discussed. These inter alia include the assessment and collection of corporate tax.
Chapter four analyses the impact of corporate tax incentives. This is with the aim of exploring their impacts on investment promotion. It therefore elucidates the concept of corporate tax incentives and its effects in attracting both the local and foreign direct investment.
Chapter five critically discussed the provisions of the CITA on offences and penalties in relation to investment promotion in Nigeria. It therefore gives a clear explanation of various offences and penalties under the CITA as it affects the investment promotion in Nigeria.
Finally, chapter six concludes the thesis. It therefore recapitulates the findings of the work and proposes some workable solutions to the problems discovered in the course of the research.