Section 74 — Rejection of application of advanced rulings

The relevant tax authority may reject an application for an advance ruling where it requires the rendering of an opinion, conclusion or determination regarding—

(a) the application or interpretation of the laws of a foreign country;

(b) an issue already before a court or tribunal of competent jurisdiction;

(c) the interpretation of the Constitution of the Federal Republic of Nigeria;

(d) an issue that is academic, hypothetical, frivolous or vexatious; and

(e) a ruling that will interfere substantially with an ongoing audit, investigation or other proceeding involving the applicant or persons connected to the applicant.