Benedicta Onyeodi

Benedicta is a Senior Associate in the Tax Practice Group of TEMPLARS. She advises clients on a broad range of Nigerian tax matters, including transaction structuring, mergers and acquisitions, corporate reorganisations, tax due diligence, cross-border investments, tax advisory and tax disputes.

Prior to joining TEMPLARS, Benedicta was a Manager in the Tax, Regulatory and People Services practice of a leading Big Four accounting firm, where she advised multinational and local clients on complex tax, regulatory and transactional matters. Her experience includes advising on tax disputes before the Tax Appeal Tribunal and superior courts of record, as well as mergers and acquisitions, business restructurings and cross-border transactions.

Benedicta is a Chartered Tax Practitioner and is currently pursuing the ACCA qualification. She was recognised by the Chartered Institute of Taxation of Nigeria as the Best Overall Graduating Student in 2020. In 2024, she was recognised by ACCA Nigeria as the 3rd Best Graduating Student in Audit and Assurance.

A Selection Of Relevant Experience

• Conducted tax due diligence reviews of Nigerian target companies in connection with proposed M&A transactions and advised on the tax and regulatory considerations arising from post-acquisition restructuring initiatives.
• Advised on the tax and regulatory implications of the proposed transfer of a c.55,000 sqm waterpark development from a Nigerian real estate developer to its wholly owned subsidiary, including alternative capitalisation structures, treatment of development costs, Pioneer Status Incentive eligibility and structuring options to facilitate future divestment while retaining operational control.
• Advised UACN on the tax implications of the proposed merger of UAC Foods Limited and CHI Limited, including acquisition structuring, foreign-funded acquisitions, group reorganisation considerations and tax-efficient implementation strategies.
• Represented two multinational companies engaged in petroleum operations in tax proceedings relating to stamp duty assessments exceeding US$214 million issued by the Federal Inland Revenue Service.
• Represented Abuja Electricity Distribution Company (AEDC) in tax proceedings relating to VAT and withholding tax assessments issued by the Federal Inland Revenue Service. The matter subsequently proceeded to the Federal High Court, which set aside the Tax Appeal Tribunal’s decision and directed a retrial before a differently constituted panel.
• Advised a leading digital payments and e-commerce company on the Nigerian tax implications of a proposed acquisition by a special purpose acquisition company (SPAC), including alternative transaction structures.
• Advised a private equity investor on the Capital Gains Tax implications of a proposed investment and evaluated alternative structures for implementing the transaction.
• Advised a multinational telecommunications group on the Nigerian tax and regulatory implications of a multi-jurisdictional corporate reorganisation, including the restructuring of Nigerian and offshore shareholding arrangements.

Professional Memberships

• Nigerian Bar Association
• Associate Member, Chartered Institute of Taxation of Nigeria

Expertise

Tax