Appraising the Public Notices issued by the Lagos State Internal Revenue Service and the Joint Tax Board

So, with the various exemptions created under Section 91(1), it is doubtful if the JTB can validly apply its Public Notice to the generality of employees as intended.

Fourth, and finally, while it appears the tax authorities have some measure of discretionary powers under Section 17(1) of the PITA, to classify any disposition as artificial or fictitious and the relationship existing between an employee and an employer on the one hand and that between an employee, an employer and a PFA on the other, both fall within the purview of the wide discretion granted under Section 17(3)(b), it is not clear whether pension contributions, which are usually not taxable in many jurisdictions globally, in order to encourage savings and stimulate provident funds among the populace; could validly be grouped with the certain transactions affected by Section 17(3)(b) of PITA.