A decision of a case entitled “Nigeria Agrip Co. Ltd v. Federal Inland Revenue Service (10th December 2014)” has been issued by the Tax Appeal Tribunal and it states that dividends paid by a gas exploration and production company and paid out of profits from the company’s gas operations in Nigeria, are considered as withholding tax. According to section 11(2) of the Petroleum Profits Tax Act, the Tribunal has decided to apply income tax law to the dividends.