Chibuike Ikefuna is an Associate in Templars Lagos Tax Practice Group.
He specializes in tax policy, planning, transactions and tax dispute resolution. Chibuike serves clients in various industries including FMCG, energy and infrastructure, fintech and telecoms and his experience ranges from corporate taxation, M&A tax, to stamp duties, customs and excise taxation and value added tax. His experience includes cross-border tax planning and treaty focused tax structuring.
Chibuike graduated with a second-class upper division from the University of Nigeria and the Nigerian Law School.
Representative experience
Tax (transactions)
- Advised a Nigerian upstream oil and gas company with shares and debt assets in related entities in Europe on the tax implications and tax efficient structure of its transaction involving exchange of debt assets for additional shares. The advise considered the double tax agreement (DTA) between Nigeria and the UK and Netherlands.
- Advised two separate Fast Moving Consumer Goods Companies on the tax considerations around their merger intention and indicated legal opportunities to limit value added tax, corporate income tax, capital gains tax and stamp taxes to be paid.
- Advised a company resident in Singapore on its service contract with its parent company in Switzerland and third-party shipping companies regarding freight income generated from Nigeria and the risks of creating a permanent establishment in Nigeria based on the DTA between Nigeria and Singapore.
- Advised on a successful application for a company on the question of whether a distant indirect related party of a limited liability company in Nigeria was capable of being an ‘associated company’ for the purpose of Section 104 intra-group relief from stamp duty.
Tax (dispute resolution)
- Successfully argued against a procedure requiring a multinational oil and gas company to deposit 50% of the disputed tax assessment of over $US200 million as a condition for being heard on appeal.
- Representing a multinational oil and gas company in a tax dispute involving withdrawal of balancing allowance claimed by the company on disposal of certain assets which are subject of a finance lease.
- Representing a multinational company in a tax dispute of over $US3 million regarding WHT payments on management fees.
Professional memberships
Nigerian Bar Association
Taxation Committee, Nigerian Bar Association Section on Business Law (NBA-SBL)
