NRS files criminal charges against Sterling Global Oil, CEO over OML 146 tax liability

The Nigeria Revenue Service (NRS) has filed criminal charges against Sterling Global Oil Resources Limited (SGORL) and its Chief Executive Officer, Deepak Baro, over petroleum royalty obligations and alleged nine-year tax liabilities linked to Oil Mining Lease (OML) 146.

The case is contained in a charge sheet marked FHC/ABJ/CR/530/2026. It is one of the latest suits by Nigeria’s apex tax agency against major companies. The NRS is also suing Binance over alleged failure to collect and remit various categories of taxes to the Federation.

Three-count charge

The three-count charge was filed by Moses Ideho, Esq., counsel to the NRS. The agency said SGORL, a company incorporated under Nigerian law, and Baro were served with a notice under Section 57 of the Nigeria Tax Administration Act, 2025.

The notice required them to produce documents, records and information on petroleum royalty obligations for OML 146 between January 1, 2016, and December 31, 2025. They allegedly failed, refused or neglected to comply by not producing the required books, documents, records and information. A reminder notice dated June 15, 2026, was sent to the company, but it allegedly failed to comply. The NRS said this offence is contrary to Section 57 and punishable under Section 130(1) and (2) of the Nigeria Tax Administration Act, 2025.

Count two accuses the company of concealing tax information. It reads: "That you, Sterling Global Oil Resources Limited and Mr. Deepak Baro, on or about the 9th day of May 2026 and within the jurisdiction of this Honourable Court, being a taxable person within the meaning of the Nigeria Tax Act, 2025, having been served with a notice pursuant to Section 57 of the Nigeria Tax Administration Act, 2025, issued by the Nigeria Revenue Service, requiring you to produce for examination, books, documents, records and information relating to your petroleum royalty obligations in respect of Oil Mining Lease 146 (OML 146) for the period 1 January 2016 to 31 December 2025, and having failed, refused and/or neglected to comply with the said notices, did thereby conceal and withhold, aid and abet information material to the ascertainment of your tax liability, which conduct facilitated the evasion of petroleum due and payable to the government of the Federation and thereby committed an offence contrary to Section 57 and punishable under Section 118 of the Nigeria Tax Administration Act, 2025."

In count three, Ideho accused the defendants of obstructing, hindering and impeding the NRS and its authorised officers in the performance of their functions and the exercise of their powers under the Nigeria Tax Administration Act, 2025.

Court appearance

The matter was listed before the Federal High Court presided over by Justice Inyang Ekwo on Wednesday. It was listed for plea, meaning the defendants were expected to be arraigned. The case did not proceed as scheduled and was adjourned to January 27, 2027, for plea.

SGORL is an indigenous company that entered Exploration and Production (E&P) in 2006. It participated in a bidding held by the Department of Petroleum Resources (DPR) and won the licence for OML 146, formerly OPL 277.

Other tax cases

The NRS case adds to tax suits by Federal Government agencies. In October 2026, the Independent Corrupt Practices and Other Related Offences Commission (ICPC) withdrew its court case against Sterling Oil Exploration & Energy Production Company Limited (SEEPCO) after settling its investigation into alleged $2.3 billion tax evasion involving the company. The commission had alleged that the oil company under-declared its daily oil production to evade taxes on production income.