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Trust and Efficiency in Tax Administration: The Silent Role of Policy-Based Legitimate Expectation in Nigeria

The interaction between tax administration, discretion and legitimate expectation has been widely explored. However, the subject has traditionally been approached from the perspective of legality and deeply focused, normatively, on how courts adjudicate cases bordering on the frustration of legitimate expectation by tax authorities. This is unsurprising, given that legitimate expectation evolved as a judicial remedy to check administrative unfairness and to provide certainty and trust in public administration. Cases show that this remedy is rarely accorded by the courts, which makes its efficiency questionable. Using Nigeria as a case study, this doctrinal paper explores the prospects of an alternative approach; one that focuses on what tax authorities, rather than the court, can and, perhaps, should do when confronted with claims of legitimate expectation and how what they do is more likely to impact public trust in the tax system. The concept of “trust” has played a useful role in shaping the jurisprudence of legitimate expectation. Some authors, likewise, advocate trust as the core underlying principle or justification for the protection of legitimate expectation. It is, however, the view of this author that, regarding taxation especially, adjudication is not a plausible way to engender trust between taxpayer and tax authority. Rather, only an approach that sees the tax authority leading, positively, on claims of legitimate expectation can engender trust. This approach can better make the tax paying public trust tax authorities, since trust is more likely to derive from a symbiotic interaction between interested parties than through an intervener.