Hello Professionals,

I am seeking opinion on the interpretation and practice of Section 10(5) of PITA 2011 as amended (extracted below) with respect to the above subject.

Notwithstanding any provision of this section, the gains or profits of an individual from any

employment as a seafarer, other than any such employment in the Nigeria Navy or the Nigeria

Ports Plc, shall be deemed to be derived from Nigeria only [/b]during any period in which the

individual is serving under articles which he had [b]signed in Nigeria [/b]or is performing [b]stand-by

duty on board a ship preparatory to his signing articles in Nigeria.


It would help to know if there is any pending and/or decided case(s) on this subsection.