www.templars-law.com

TAX PRACTICE

At Templars, we provide innovative and practical advice on Tax Governance Strategy and Dispute Resolution Services on a standalone basis or as an integral part of the firm's enterprise risk management process where we help clients optimize value.

We understand the business and legal intricacies of international taxation and have an unrivalled ability to design, implement and defend our clients' tax planning structures.

Our team offers outstanding Tax Advisory Services in all key finance and business transactions spanning Mergers and Acquisitions, Joint Ventures, Private Equity, International Planning, Capital Formation, Real Estate, Tax‐exempt Finance and State and Local Tax Matters.

Our Tax Practice

"Clients are positive about the team's commercial nous and ability to “get to the

crux of the specific challenges”

- Chambers Global Guide to the Legal Profession, 2014 edition

www.templars-law.com Tax Practice 02

Successfully represented Phillips Oil Company Nigeria Limited, a subsidiary of ConocoPhillips, in a tax appeal challenging the Federal Inland Revenue Service's decision to exclude interests incurred on intra‐group or related company loans in its computation of the company's petroleum profits tax liability for its petroleum operations.

Represented ExxonMobil in successful conciliation proceedings with the Department of Petroleum Resources in a US$280 million Reserves Addition Bonus dispute arising from the 2000 Memorandum of Understanding between Nigerian Government and IOCs.

Represented Phillips Oil Company (Nigeria) Limited at the Tax Appeal Tribunal in respect of its dispute with the Nigerian government.

Currently representing the Erha Contractor Group in several tax appeals at the Lagos Zone of the Tax Appeal Tribunal (TAT) against wrongful PPT and EDT assessments and decisions of the FIRS.

Advised an energy multinational on regulatory‐optimal options (and related implications) for Group restructuring towards eligibility for Bilateral Investment Treaty relief, ahead of potential investment dispute with the Nigerian Government.

Advised Halliburton Energy Services Nigeria Limited in its multi‐million dollar tax dispute with the FIRS. Templars was part of a multidisciplinary team (comprised of law and accounting firms) that successfully challenged the ruling of the Body of Appeal Commissioners (BAC) at the Federal High Court disallowing recharges of sub‐contract cost in computation of the company's deemed profits in respect of a contract with an oil major in Nigeria.

Recent Disclosable Matters

Currently representing ExxonMobil and Shell as Contractor Parties to a Production Sharing Contract in six separate tax appeals at the Tax Appeal Tribunal challenging FIRS' wrongful computation of Education Tax and Petroleum Profits Tax assessments.

Represented and secured a Landmark Judgment in favour of Total E & P Nigeria Limited in a dispute concerning the application of the Official Selling Price as opposed to Realisable Price in the computation of the petroleum profits tax liability for Total's JV operations.

Represented and resolved various tax issues on behalf of several multinational companies (in various sectors) with the FIRS and State Boards of Internal Revenue (SBIR). Engagements included status reviews, provision of advice on strategy/review of strategy for resolution of tax issues, and implementation assistance, negotiation of tax liabilities/penalties with the Revenue.

Advised FMC Technologies Limited on the applicability of tax and regulatory consideration relating to dividends and intercompany loans.

Successfully represented and secured a landmark judgment in favour of Total E&P Nigeria Limited in a tax appeal against the FIRS' refusal to recognize as tax deductible gas flaring fees paid by Total to the Nigerian Government.

"The team is described as "engaging" and "insightful" and "one of the better firms in terms of service".

- IFLR, 2013 edition

www.templars-law.com Tax Practice 03

OFFICE LOCATIONS

Lagos

5th Floor, The Octagon

13A, AJ Marinho Drive

Victoria island

Lagos

Tel: +234 1 46 11 294, +234 1 2703982

+234 1 2799396, +234 1 4611889-90

Fax: +234 1 27 12 810

Email: info@templars-law.com

Abuja

3rd Floor, Metro Plaza

Plot 991/2, Zakaria Maimalari Street,

Central Business District

Abuja

Tel: +234 9 273 1898

+234 9 273 1877

www.templars‐law.com

www.linkedin.com/company/templars

twitter.com/templars_law

Key Contacts

Dipo KomolafePartnerTax AdvisoryT: +234‐1‐271 3065E: Dipo.komolafe@templars‐law.com

Adewale AtakePartnerTax Litigation T: +234 1‐279 9398E: adewale.atake@templars‐law.com