Wednesday, 4 September 2013

ASPECTS OF TAX CRIMINALITY IN NIGERIA


                                       ASPECTS OF TAX CRIMINALITY IN NIGERIA

                            M.T.Abdulrazaq  LLB(ABU) LL.M(LSE) PhD (ABU) BL ACIArb FCIB FCTI.

                            Professor of Taxation, Faculty of Law, Lagos State University .

Introduction

This article is concerned with the tax practitioner's  own position when his client or employer has become, or seems  likely to become, involved with the criminal law. The tax practitioner in those circumstance needs to be alive to the possibility of himself infringing the provisions of the criminal law. This is an aspect which has so far received little attention.

It must be clear, however, that this article makes no claim  to being an exhaustive guide but one that simply draws attention  to some areas of the criminal law of which the tax  practitioner may be unaware or has forgotten. Expert legal  advice should be sought whenever a tax practitioner is in doubt about his own position.

1. Cheating

a.Section.321 of The Penal Code Law, 1959 (Northern Region  No. 18 of 1959)

(See generally Notes on the Penal Code Law (1959) S. S. Richardson, Government Printer, Kaduna).

The above section provides that whoever by deceiving any person

a.fraudulently or dishonestly induces the person so deceived to deliver any property to any person or to consent that any person shall retain any property; or

b.intentionally induces the person so deceived to do or omit to do anything which he would not do or omit to do if he were not so deceived and which act or commission causes or is likely to cause damage or harm  to that person in body, mind, reputation or property, is said to cheat.

 Explanation

A dishonest concealment of facts is a deception within the meaning of this section and is akin to the U.K offence of cheating the public revenue. See also Hudson (1956) 2QB
252. This also inevitably leads to the offence of tax evasion.

Comment

(i)The definition of the offence of cheating embraces some cases in which no transfer of property is caused
as a result of the deception and some in which a transfer does occur; for these cases generally, provision is made in section 324. For the cases in which property is transferred, a more specific provision is made in section 326.

(ii)The original authors of the Penal Code said:
‘’ propose to make it cheating to obtain property by deception in all cases where property is fraudulently obtained".

In the definition of cheating in section 320 there are set forth two separate classes of acts which the person deceive may be induced to do. In the first place he may be induced to deliver any property to any person or to consent that any person shall retain any property. In order to constitute the offence of cheating, the person who induces another to do this class of act must do so fraudulently or dishonestly.
The second class of acts set forth in the section is the doing or omitting to do anything which the person deceived would not do or omit to do if he
were not so deceived. In order to constitute the offence of cheating with regard to this class of acts, the person who induces another to do them must intentionally induce him to do them. In the first class of acts, the inducement must be fraudulent or dishonest. In the second class of acts, the inducement must be intentional.

(iii). The distinction between breach of contract and cheating depends upon the intention of the accused at the time of the alleged inducement which may be judged by his subsequent act but of which the subsequent act is not the sole criterion. Mere breach
of contract does not normally give rise to a criminal prosecution, but see section 381 for an exceptional case
.

(iv). The offence of cheating must be committed by the wrongful obtaining of a consent. The difference between this offence and that of extortion is that in extortion the consent is obtained by intimidation and in cheating the consent is obtained by deception.

(v) Cheating is a complete offence by itself and is not a form of criminal breach of trust. A person who tricks another into delivering property to him bears no resemblance to a trustee in the ordinary accepted meaning of that term.

 

 (vi) Note the difference between "fraudulently" and "dishonestly" see section 16 and 17.
2.       Incitement to Commit a Criminal Offence

It has been said that an inciter is one:

‘Who reaches and seeks to influence the mind of another to the commission of a crime... The approach to the others mind may take various
forms) such as suggestion) proposal) request) exhortation) gesture) argument) persuasion) inducement) goading or the arousal of cupidity’

(Homes J. A. in Nkosiyana, 1966 (4) SA 655 at 658 AD). Smith and Hogan's Criminal Law (7th edition at page 268)
says as to the mental element:

it must be proved that (the accused) knew of (or deliberately closed his eyes to) all ',the circumstances of the act incited which are elements of the crime in question)).

Where incitement is tried on indictment, 'it is punishable with fine and/ or imprisonment at the discretion of the court. if however:

"It is tried summarily, the offender is not liable to any greater penalty than he would

be liable to on summary conviction of the completed offence))

(Smith and Hogan 7th ed. at pg. 267).
3.       Conspiracy

(a) Section. 96 of The Penal Code Law (Northern Region No.  18 of 1959) provides that:
1.     when two or more persons agree to do or cause to be done

(a) an illegal act; or

(b) an act which is not illegal by illegal means, such an agreement is called a criminal conspiracy.
 
2.Notwithstanding the provisions of subsection (1), no agreement except an agreement to commit an offence shall amount to a criminal conspiracy unless
 some act besides the agreement is done by one or more parties to such agreement in pursuance thereof.

Explanation

it is immaterial whether the illegal act is the ultimate object of such agreement, or is merely incidental to that object.
This section shall not apply to an agreement of two or more persons to do or cause to be done any act in contemplation or furtherance of a trade dispute if such act committed by one person would not be punishable as an offence. Nothing in this section shall exempt from punishment any person guilty of a conspiracy for which a punishment is provided by any Ordinance or other Law.

1. Comment

1.Conspiracy is distinguished from other offences in that the crime consist simply in the agreement or confederacy to do some act, no matter whether it is done or not. In other offences, the intention to do a criminal act is not a crime of itself until something is done amounting to the doing or attempting to do some act to carry out the  intention. Section 96 codifies English Law in this matter.

2.Where, a conspiracy amounts to an abetment within the definition in section 83, there is no need to proceed under section 96 as conspiracy of that type is specifically provided for in section 83.

3.A mere agreement between 'two or more persons to  commit an illegal act or .lawful act by unlawful means is sufficient to constitute the offence.

4.      Explanation above is designed to save the activities of trade unions and associations. Within the background of a trade, it is lawful for two or more persons to do an
act in contemplation or furtherance of the dispute provided that such an act is lawful if committed by one person.

(b) Section 516 of Criminal Code Act Cap. 77 of Laws
of Federation of Nigeria

Provides that any person who conspires with another to commit any felony, or to do any act in any part of the world which if done in Nigeria would be a felony, and which is an offence under the laws in force in the place where it is proposed to be done-is guilty of a felony, and is liable, if no other punishment is provided, to imprisonment for seven years, or, if the greatest punishment to which a person convicted of the felony in question is liable is less than imprisonment for seven years, then to such lesser punishment.

(c) Section 516A of same act further state that any person who while in a State conspires with another to do any act not in the State which if done in the state would be a felony against the law of the State and which is an offence against the law of the place where it is proposed to be done, is guilty of a felony and is liable, if no other punishment is provided, to imprisonment for seven years, or if the greatest
punishment to which a person convicted of the felony in question is liable is less than imprisonment for seven years, then to such lesser punishment
.

In this section and section 517A, "law of a state" has the meaning assigned to it in section 10A of this code.

(d) Section 517 of the same act also provides that any person who 'conspires with another to commit any offence which is not a felony, or to do any act in any part of the world, which if done in Nigeria would be an offence but not a felony, and which is an offence
under the laws in force in the place where it is proposed to be done
, is guilty of a misdemeanor  and is liable to imprisonment for two years. The offender cannot be arrested without warrant.

(e) Section 517 A also provides that any person who while in a State conspires with another to do any act not in the State which if done in the State would be an offence against the law of the State (other than felony) and, which is an offence against the law of
the place where it is proposed to be done is guilty of misdeamenour and is liable to imprisonment for two years. The offender cannot be arrested without warrant
.

(f) Section 518 of the same Criminal Code Act Cap 77 of the Law of Federation of Nigeria provides that any person who conspires with another to effect any of the following purposes:
i.      prevent or defeat the execution of enforcement  of any Act, Law, Statute, or Order; or .

  II. to cause any injury to the person or reputation of any person, or to depreciate the value of any property of any person; or

iii. to prevent or obstruct the free and lawful disposition of any property by the owner thereof
for its fair value; or

IV. to injure any person in his trade or profession; or
v.       to prevent or obstruct, by means of any act or acts which if done by an individual person would constitute an offence on his part, the free and lawful exercise by any person of his trade, profession, or occupation; or .

VI. to effect any unlawful purpose; or

 vii. to effect any lawful purpose by any unlawful  means; is guilty of a misdemeanours, and is liable to imprisonment for two years. An offender cannot be arrested without warrant.

(g) Section 518A also provides that the provisions of section 516 to 518 shall not apply to an agreement or combination of two or more persons to do  procure to be done any act in contemplation or
furtherance of a trade dispute if such act committed by one person would not be punishable as an offence: provided that nothing in this section shall exempt from punishment any persons guilty of a conspiracy for which a punishment is provided by any other
enactment:

And provided further that nothing in this section shall affect the law relating to riot, unlawful assembly, breach of the peace, or sedition, or any offence
against the state
.

For the purposes of this section however- "offence" does not include an offence punishable only by fine; and "trade dispute" has the same meaning as in the
Trade Unions Act
.

4. Section 171 Penal Code Law, 1959

This section provides that whoever intentionally offers any resistance or illegal obstruction to the lawful arrest of any other person or rescues or attempts to rescue any other
person from any confinement or custody in which that person is lawfully deta
ined, shall be punished

(a) with imprisonment for a term which may extend to 7 years or with fine or with both;and

(b) if such other person is under sentence of death, shall be punished with imprisonment which may extend to imprisonment for life and shall also be liable to fine.

Comment:

The intention of the accused is an important ingredient of the offence. If the arrest is itself not lawful, then resistance to the arrest will not be an offence under this section.
Similarly, the person from whose custody a rescue is effected must have authority to detain lawfully the person rescued or no offence will have been committed in the rescue.

5.. Section 513 of Criminal Code Act
This section provides that:

1.       Any person who attempts to procure another to do an act or make an omission of such a nature if he himself were to do the act or make the omission he would be guilty of an offence, is himself to be deemed guilty of attempting to commit such offence
and to be punishable ac
cordingly.

2.Any person who while in Nigeria attempts to procure another to do an act or make an omission at a place not in Nigeria of such a nature-

a.that if he were himself to do the act or make the omission in Nigeria he would be guilty of an offence; and

b.that if he were himself to do the act or make the omission at the place where the act "or omission is proposed to be done or made he would himself be guilty of an offence under the laws in force at that place, is guilty of an offence of the same kind
and is liable to the same punishment as if he were himself to attempt to do the same act or make the same omission in
Nigeria.  See 1 RC V. Rossminster Ltd (1980) All ER 80.

 

6.            Personal Income Tax Act 2004

1)            Section 105 of this Decree provides as follows:

Any person who-

a.          having been required to give information under the provisions of the preceding section wilfully obstructs a Tax Collector in the performance of his duties by neglecting or refusing to give such information; or

b.        otherwise obstructs or wilfully misleads or attempts to mislead a Tax Collector in the performance of his duties under this part of this Act is guilty of an offence under this Act.

2)            Section 97 of the same Act also provides that:

A person who –

(a)          being a person appointed for the due administration of this Act or employed in connection with the assessment or collection of the tax –

(i)            demands from a person an amount in excess of the authorized assessment of the tax;or

(ii) withholds for his own use or otherwise,a portion of the amount of tax collected;or

(iii) renders a false return,whether orally or in writing,of the amount of tax collected or received by him;or

(iv) defrauds a person,embezzles any money,or otherwise uses his position to deal wrongly with the relevant tax authority;or

(b)          not being authorised under this Act to do so,collects or attempts to collect the tax under this Act,

 is guilty of an offence and liable on conviction to a fine of N1000 or to imprisonment for three years or both such fine and  imprisonment.  
See  C.O.P v. Amadu of Awe 1 NTC 30: Hellel v. A.C.l
.T 1 NTC 33; Nakade v. Jos Native Authority 1 NTC 118.

  
Conclusion

It will be clear from the foregoing that there are possible perils for the tax practitioner when a client is involved, or potentially involved with the criminal law. It seems that the
first precaution a practitioner needs to take is to avoid  becoming too closel
y identified with his client and his client's position. It means perhaps keeping a segment of his mind
detached. Most practitioners will probably do this automatically in order to maintain an objective view of the situation in the client's own interest
. A little more than that is, however, required: an awareness that the practitioner could be at risk personally unless appropriate further precautions are taken, we hope this will be of  some help in indicating the form those precautions should take.

 Finally, we would stress again the need for expert legal advice if the practitioner is in any doubt of the legal effect of a course of action he is contemplating on behalf of his client or employer.  

 

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