BRITISH PETROLEUM VS. THE NIGERIAN GOVERNMENT: THE CAPITAL GAINS TAX DISPUTE, 1972–9

This article documents a landmark dispute between British Petroleum (BP) and the Nigerian tax authorities that occurred over a N130 million (£100 million) capital gains tax assessment arising from an intra BP Group transfer of its 50 per cent shareholding in Shell/BP Nigeria. This was necessitated by a BP transaction in Abu Dhabi. This tax assessment, which was more than twice the yearly cash flow of BP's Nigerian operations at the time, ignited a chain of events and schemes that saw the British government covertly and overtly providing support to BP, with the primary goal of influencing the outcome of the dispute in order to protect the interests of both the British government and BP. Evidence in this article highlights the complexities of postcolonial relationships between centre countries and African ex-colonies.