Mr. Amaefule is a member of the Firm’s Energy & Natural Resources and Corporate/Commercial Practice Groups. His core specializations are corporate taxation, upstream tax and fiscal systems, petroleum and minerals law and policy and international petroleum contracts. His petroleum revenue tax advisory experience is extensive and includes involvement in the landmark PSC disputes between the IOCs and both the NNPC and FIRS, advice on the tax treatment of upstream divestments, IOC/NNPC carry arrangements and deepwater projects.
He has been involved in certain landmark cases, one of which was when he successfully argued against a VAT assessment on the assignment of a PSC contractor’s interest. In a later case, he successfully argued that the principle of legitimate expectation should preclude the FIRS from reneging on an earlier representation that tax credit (and not tax allowance) applied to a PSC.
Mr. Amaefule advised an international container company on whether its freight and demurrage were liable to income tax, advised a foreign company on whether its EPC profits were liable to tax and represented an international airline in its income tax dispute with the FIRS. He is currently conducting the defence of two related multinational oilfield services companies regarding their PAYE tax disputes with the LIRS involving disputed assessments of N25b.
His experience in the oil and gas industry includes advisory on crude oil lifting disputes between IOCs and NNPC, and the legal regime for the acquisition of OMLs and marginal fields. He also assists clients in analyzing international petroleum agreements.
Mr. Amaefule has advised on the corporate structure of a mineral project for the development of a globally acclaimed discovery in Nigeria’s North-West with the objective of ensuring a tax efficient arrangement in relation to capital allowances and loss deductibility, income tax relief incentive and tax saving benefits of large scale operations. He routinely advises the project on diverse areas of Nigeria’s mineral regime.
Mr. Amaefule lectured “Principles of Taxation” and “Oil and Gas Tax” to student members of the CITN.