Taxpayer Rights, Administrative Justice, and Compliance in the Nigerian Tax System: A Constitutional Perspective

This doctoral study develops a constitutional and administrative law analysis of taxpayer rights within the Nigerian tax system and examines, through original empirical research, how the protection or violation of these rights affects tax compliance behaviour. The constitutional dimensions of taxation, grounded in the Nigerian Constitution's provisions on fundamental rights, due process, and non-discrimination, have been insufficiently integrated into the tax administration literature, which has focused primarily on economic incentive models of compliance. The study identifies the normative content of taxpayer rights in Nigerian law through systematic constitutional interpretation, judicial review of leading Supreme Court and Court of Appeal tax decisions since 2000, and comparative analysis of taxpayer rights charters in South Africa, Rwanda, and the United Kingdom. An original taxpayer rights protection index is constructed for Nigeria, scored on ten dimensions including right to information, right to objection, right to appeal, and protection from arbitrary assessment. Empirical testing uses a quasi-experimental design exploiting regional variation in Tax Appeal Tribunal effectiveness to identify the causal effect of administrative justice quality on filing compliance rates in a panel of state-level data. The study expects to find that regions with better-functioning TAT benches demonstrate significantly higher compliance rates, consistent with procedural justice theory. Theoretical contributions include a constitutional rights-based model of tax compliance extending the Kirchler cube framework. Keywords: taxpayer rights, administrative justice, constitutional law, Tax Appeal Tribunal, compliance.