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Jibrin Dasun is a Senior Associate within the Tax and Corporate/Commercial Teams in the Lagos office of ǼLEX. He regularly advises on corporate/commercial transactions focusing on the tax (direct and indirect) issues affecting inbound and outbound investments. In this respect, Jibrin has been involved in the following matters:

• advised an IOC on the tax-structuring of an acquisition of an oil field interest worth over US$1.2 billion, including the availability of a step up in capital allowance basis in connection with the acquisition;
• provided tax advice to a global cloud services provider in respect of its expansion into Nigeria in light of the introduction of digital ‘permanent establishment’;
• provided tax-structuring advice to a South African-financial services group — Africa’s biggest lender — in respect of its securities lending transactions in Nigeria;
• advised an IOC on the tax implication of an oil field adjustment worth approximately US$1.1 billion;
• advised a global social media company on the Nigerian tax implications of its cross-border payments platform;
• provided tax-structuring advice to a European international airline in respect of the taxation of its income from outbound freight in Nigeria, and successfully represented the airline in claiming a tax exemption from its outbound freight income based on a Double Tax Treaty;
• provided tax-structuring advice to an indigenous oil company on its proposed acquisition of interests in two oil blocs in Ghana;
• currently providing tax-structuring advice to Africa’s largest privately-owned investment management company in respect of its unit trust investment scheme in Nigeria; and
• advising several multinational companies on the tax, securities law, and exchange control implications of their employee share compensation plans in Nigeria.

Jibrin  routinely represents several MNEs and local companies in tax disputes regarding all aspects of the Nigerian tax regime before the Tax Appeal Tribunals and superior courts of records in Nigeria. He is a key member of the team that successfully handled tax disputes involving a cumulative sum of US$4billion on behalf of a number of IOCs (Shell, Total, Exxon Mobil, Chevron, and CNOOC) involving various upstream tax issues. Some of which include the deductibility of expenses (including related-party interest expense and sole costs) under the JV and the PSC regimes, and the taxation of capital and investment allowances and balancing charges. Jibrin’s tax litigation matters include:

• representing the OML 130 contractor parties at the Federal High Court in a landmark claim for tax refundof US$1.8 billion jointly and severally from the NNPC and the FIRS;
• representing the Michelin group at the Tax Appeal Tribunal in a ground-breaking transfer pricing dispute against the FIRS worth N1 billion;
• representing Chevron in an appeal by the FIRS against the TaxAppealTribunal’s discharge of petroleum profits tax assessments in the combined sum of US$800 million regarding Chevron’s gas utilisation projects.

Jibrin is also key member of the firm’s Banking and Finance practice focusing on the e-payment industry. He is part of the team advising a leading global card scheme company on its Nigerian operations. He advises a broad range of clients on the regulatory and exchange control issues that affect inward investment, repatriation of profits and capital.

Certifications

Advanced Diploma in International Taxation (ADIT) of the Chartered Institute of Taxation of the United Kingdom (2018)
BL, Nigerian Law School (2013)
LL.B, University of Ilorin (2012)

Professional Association

International Tax Affiliate of The Chartered Institute of Taxation, UK
Associate of the Chartered Institute of Taxation of Nigeria
Member, International Fiscal Association
Member, Taxes Committee of the International Bar Association
Member, Nigerian Bar Association