Chapter One — 1.1 Background to the Study

The Nigerian legal system has, over time, sought to address tax evasion through instruments such as the Federal Inland Revenue Service (Establishment) Act, yet questions remain about how effectively the law achieves its intended purpose in practice.

While the legal framework addressing tax evasion has evolved considerably, regulatory gaps remains an area where scholarly and judicial opinion is divided, warranting closer legal analysis.

1.2 Statement of the Problem

Notwithstanding the provisions of the Federal Inland Revenue Service (Establishment) Act, tax evasion persists in Nigeria, raising concerns about regulatory gaps and whether the current legal regime is adequate to the task. This study interrogates that gap between legislative intent and practical outcome.

1.3 Objectives of the Study

1. To examine the legal framework governing tax evasion in Nigeria, particularly under the Federal Inland Revenue Service (Establishment) Act.
2. To assess regulatory gaps as it relates to tax evasion.
3. To identify the gaps between the law's provisions and its practical enforcement.
4. To recommend legal and institutional reforms to strengthen the response to tax evasion.

1.4 Research Questions

1. What does the Federal Inland Revenue Service (Establishment) Act provide in respect of tax evasion?
2. What challenges arise in respect of regulatory gaps in relation to tax evasion?
3. What gaps exist between the law's provisions and its practical enforcement?
4. What reforms could strengthen Nigeria's legal response to tax evasion?

1.5 Significance of the Study

This study is significant to legal practitioners, policymakers, and law enforcement agencies grappling with tax evasion, offering a focused analysis of the Federal Inland Revenue Service (Establishment) Act and its practical adequacy. It also contributes to the growing body of scholarship in law on Nigeria's response to this issue.

1.6 Scope of the Study

The study is limited to a doctrinal and case-law analysis of tax evasion with particular focus on regulatory gaps, reflecting a clearly defined scope; it does not extend to a full empirical survey of enforcement outcomes nationwide.