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Emmanuel Onyeabor

Emmanuel Onyeabor

Emmanuel Onyeabor is a Senior Associate in the tax, employment, and commercial disputes resolution practices of Banwo & Ighodalo. He is the Team Lead of the Tax Practice in the Firm with extensive experience in providing a wide range of tailored tax (and business advisory), transactional support, and disputes resolution services to reputable multinationals and government entities. He regularly combines his legal, tax, and basic business accounting knowledge to achieve the required blend of law and business necessary for targeted client satisfaction. His core practice areas are tax, employment, and commercial disputes resolution. His tax specialty includes general corporate tax, transfer pricing, transactional tax, private client and wealth management, tax deal advisory, indirect tax, real estate tax, financial services tax, tax controversy, and consumer/industrial markets tax. Emmanuel is a member of the Nigerian Bar Association (NBA), the Chartered Institute of Taxation of Nigeria (CITN), and the Employment and Labour Lawyers Association of Nigeria (ELLAN). He was ranked as a Rising Star Leader for General Corporate Tax in the International Tax Review (ITR) Europe, Middle East, and Africa (EMEA) World Tax Practitioners Rankings 2023.

Emmanuel advised a multinational engineering and construction company on the optimal tax structure for its provision of engineering, procurement, construction, and management services to the Federal Government of Nigeria in its three-phased project designed to expand and modernise the Nigerian electricity grid in terms of generation, transmission, and distribution of electricity. Emmanuel also advised another multinational engineering and construction company on the optimal tax structure for its participation in the engineering, procurement, and construction deal relating to the execution of a federal plant project in Nigeria. Emmanuel further advised a multinational oil and gas company and a government entity, on the optimal tax structures for their gas-to-liquids joint venture project and the domestication of their project diesel products in Nigeria.

In 2019, Emmanuel successfully represented and obtained favourable judgment for the respondent in the novel case of Allan Gray Investment Management Nigeria Ltd. v FIRS (2019) 48 TLRN 44, wherein the Tax Appeal Tribunal, Lagos Zone, established the parameters for determining exported service exempt from value added tax in Nigeria. He successfully represented the appellant in the celebrated case of INT Towers Ltd. v FIRS (Appeal No. TAT/LZ/CIT/021/2022), wherein the Tax Appeal Tribunal, Lagos Zone, held on February 3, 2023, that infrastructure service providers licensed by the Nigerian Communications Commission (NCC) to engage in turnkey infrastructure deployment (construction of tower and tower equipment) and infrastructure sharing and leasing (collocation services) for players in different industries including the telecommunications industry, are not telecommunications companies and are therefore not subject to the 1% profit before tax levy imposed on telecommunications companies under section 12(2)(a) of the National Information Technology Development Agency Act 2007.

Emmanuel also represented the claimant in Sonny Ekedayen v Rasheed Olaoluwa & Bank of Industry Ltd. (Suit No. NICN/LA/569/2015), wherein the National Industrial Court of Nigeria, Lagos Division, held on December 8, 2022, amongst other key findings, that where an employer fails to clearly and validly terminate an employee in strict compliance with the contractual terms of employment, or does so in breach of a court order or in violation of international best practices in employment relations, the employee (notwithstanding that he may be a private employee in the private employment of the employer) may be consequentially entitled to reinstatement and payment of arrears of salaries and other applicable employment benefits.

Emmanuel enjoys writing and listening to music, sketching pencil portraits, writing fictional works, reading classical books, and watching captivating movies in his free time.

EDUCATION

  • University of Nigeria (LL.B)

  • Nigerian Law School (BL)

PRACTICE AREAS

  • Tax

  • Employment

  • Commercial Disputes Resolution

MEMBERSHIP OF PROFESSIONAL BODIES

  • Nigerian Bar Association

  • Chartered Institute of Taxation of Nigeria

  • Employment and Labour Lawyers Association of Nigeria