In a major stride toward modernizing Nigeria’s fiscal landscape, President Bola Ahmed Tinubu, on 26th June 2025, signed into law four landmark Tax Reform Bills, namely:
The Nigeria Tax Act (NTA)
The Nigeria Tax Administration Act (NTAA)
The Nigeria Revenue Service Act (NRSA)
And the Joint Revenue Board Act (JRBA)
Collectively referred to as “the Acts,” these legislations represent a comprehensive overhaul of Nigeria’s tax system. They are designed to stimulate economic growth, enhance revenue generation, improve the business environment, and strengthen tax administration across all levels of government.
This article aims to outline the key provisions of the Acts and examine their implications for individuals, businesses, and the Nigerian economy at large.
The Nigeria Tax Act
The Nigeria Tax Act, 2025 (the “Act”) represents the most comprehensive reform of the nation’s tax framework in decades. It consolidates multiple existing tax laws into a single, unified code, streamlining compliance and administration. Notably, the Act repeals at least twelve major tax enactments, including the Companies Income Tax Act (CITA), Personal Income Tax Act (PITA), Value Added Tax Act (VATA), and Petroleum Profits Tax Act (PPTA), among others. This consolidation marks a decisive step toward creating a more efficient, transparent, and business-friendly tax regime in Nigeria.
Chapter 2 forms the heart of the Nigeria Tax Act, 2025, the single chapter now governs the taxation of income earned by individuals, companies, and other entities in Nigeria.
In essence, Chapter 2 serves as the primary rulebook for determining who pays tax, on what income, and how such tax is calculated and collected.
Part 1: The Foundation — Who Gets Taxed and On What?
Section 3: Imposition of Tax
What it says:
Income tax shall be imposed on the following:
Profits of any company or enterprise.
Income of any individual or family.
Income of trustees or estates.
In simple terms:
If you earn income in Nigeria — whether as an individual, a business, or through an estate — you are required to pay tax on it.
Section 4: What Kind of Income Is Taxable?
This section provides a detailed list of what qualifies as taxable income, reflecting both traditional and modern income streams.
Taxable income includes:
Business Profits: Earnings from any trade, business, profession, or vocation.
Royalties and Rents: Income from the use of intellectual property or physical property (e.g., a song, patent, or building).
Dividends and Interest: Returns on investments and savings.
Salaries and Allowances: Employment income, including bonuses, housing, or company cars.
Discounts and Prizes: Major discounts or winnings received as part of a transaction or promotion.
Gains from Property Sales: Profits from the sale of assets (now classified as “chargeable gains”).
Digital and Virtual Assets (New): Profits from trading or disposing of cryptocurrencies, NFTs, and other digital assets.
Any Other Source: A broad “catch-all” provision — if it generates income, it is likely taxable.
For Employees Specifically:
Your salary, wages, bonuses, allowances, benefits-in-kind (such as accommodation or vehicles), and pension contributions are all regarded as taxable income under the Act.
Part 2: How Residents Are Taxed
The Nigeria Tax Act, 2025 introduces a unified and clearer framework for determining how residents—both individuals and companies—are taxed on their income. The underlying principle is straightforward: if you are resident in Nigeria, you are generally taxable on your worldwide income, regardless of where it was earned.
Section 6: Nigerian Companies
Rule: A Nigerian company is taxed on its global income, irrespective of where in the world the profit was generated. As long as the company is registered or managed in Nigeria, all profits—domestic or foreign—are taxable under Nigerian law.
New Provision – Stricter Foreign Subsidiary Rules:
The Act introduces tighter controls on foreign subsidiaries of Nigerian companies to prevent profit shifting and tax avoidance.
If a Nigerian company controls a foreign subsidiary that retains its earnings instead of distributing dividends, the Nigerian parent company can still be taxed on its share of that undistributed foreign profit.
Additionally, if the foreign subsidiary is subject to very low taxes abroad, the Nigerian parent may be required to pay a “top-up tax” in Nigeria to bridge the gap.
This aligns Nigeria with global trends on controlled foreign company (CFC) rules and minimum tax standards.
Sections 9 & 10: Dividend Rules for Closely Held Companies
The Challenge:
Companies owned by a small group of shareholders sometimes retain profits rather than declare dividends, to help their owners avoid personal income tax on those dividends.
The Reform:
The Federal Inland Revenue Service (FIRS) now has the power to deem retained earnings as distributed dividends. In such cases, the individual shareholders will be taxed as though they received the dividend, even if the company never actually paid it out.
This prevents tax avoidance through indefinite profit retention in closely held or family-owned companies.
Section 12: Resident Individuals
Rule:
Just like companies, Nigerian residents are taxable on their worldwide income. This means income earned abroad—whether from employment, investments, or business—must be declared and may be taxed in Nigeria.
New Progressive Personal Income Tax (PIT) Regime:
The Nigeria Tax Act, 2025 introduces a more progressive PIT system:
Individuals earning ₦800,000 or less per annum are exempt from tax on income and gains.
Higher income earners are taxed at graduated rates up to 25%, depending on the income bracket.
The Act also increases the tax exemption threshold for compensation for loss of employment or injury from ₦10 million to ₦50 million.
Key Takeaway:
These changes aim to relieve low-income earners, ensure fairer taxation, and provide stronger protection for individuals receiving employment-related compensation.
However, foreign tax credits may be available to avoid double taxation where similar income has already been taxed in another country.
Section 13: When is Your Salary Taxed in Nigeria?
Your employment income will be taxed in Nigeria if any of the following apply:
You are resident in Nigeria.
You perform your work in Nigeria, and your employer is based or has a fixed presence in Nigeria.
New Exception: If you are a non-resident working for a foreign tech, digital, or creative enterprise and you already pay tax on that salary in your home country, you may be exempt from Nigerian income tax.
This new rule aims to attract global digital talent and encourage cross-border employment in the Nigerian economy.
Section 14: Benefits-in-Kind — The “Hidden” Salary
What It Means:
When your employer provides non-cash benefits—such as a car, free accommodation, or a subsidised loan—these are known as benefits-in-kind (BIK).
How It’s Taxed:
Each benefit is assigned a monetary value, which is added to your salary and taxed as part of your total employment income.
Example: If your employer provides a company car, you are deemed to have received additional income equal to 5% of the car’s value per year.
Housing: If you receive free accommodation, the annual rental value (capped at 20% of your other employment income) is treated as taxable income.
These provisions ensure that both cash and non-cash compensation are taxed fairly and transparently.
Part 3: How Non-Residents Are Taxed
The Nigeria Tax Act, 2025 introduces clear rules for foreign companies and individuals doing business in Nigeria. A non-resident is liable to pay tax in Nigeria if they meet either of the following criteria:
Permanent Establishment (PE): A fixed place of business in Nigeria, such as an office, factory, or mine.
Significant Economic Presence (SEP) — New: Even without a physical office, a foreign company can be taxed if it has a substantial economic presence in Nigeria. This includes:
Digital services: E-commerce platforms, streaming services, app stores, online advertising, cloud computing, and similar activities.
Targeting Nigerian customers digitally triggers tax liability.
Deemed Profit Rule:If actual profits earned in Nigeria cannot be easily determined, the tax authority may calculate a deemed profit based on the company’s global accounts and apply Nigerian taxation accordingly.
A minimum tax of 4% of total Nigerian turnover applies if no tax has been withheld at source.
Key Takeaway:
These provisions reflect Nigeria’s adaptation to modern business models and digital commerce, ensuring non-residents contribute fairly to the Nigerian tax system.
Part 4: Calculating Profits — Allowable and Non-Allowable Deductions
To determine taxable profits, the Act specifies which expenses can and cannot be deducted, providing clarity and reducing potential disputes.
Section 20: Allowable Deductions (What You Can Subtract)
Expenses must be incurred wholly, exclusively, and necessarily for business purposes. Examples include:
Rent for business premises
salaries and wages
Interest on business loans (subject to limits)
Repairs and maintenance
Pension contributions
New: Research & Development costs
New: Costs for assistive devices for employees with disabilities
Section 21: Non-Allowable Deductions (What You Cannot Subtract)
The following expenses cannot be deducted from revenue when calculating taxable profits:
Personal or domestic expenses
Capital withdrawn from the business
Taxes on income or profits
Depreciation (managed separately via a capital allowance system)
Fines or penalties
Part 8: Tax on Selling Assets (Chargeable Gains)
The Nigeria Tax Act, 2025 replaces the old Capital Gains Tax Act and modernizes how asset disposals are taxed. Almost all types of property—including shares, debts, real estate, and digital/virtual assets—are now considered chargeable assets.
Key Provisions:
Small investor exemption: Gains from selling shares in a Nigerian company are not taxable if total sales are under ₦150 million and total gains are under ₦10 million.
Disposal definition: A disposal goes beyond a sale and includes leases, transfers, gifts, compulsory acquisitions, insurance compensations, and payments for giving up rights.
Calculating gains: Gains are generally the selling price minus cost of acquisition. For business assets that received capital allowances, the gain must be calculated using the residual value. (Section 39)
Compensation for loss of office: The first ₦50 million received as compensation is tax-free, with amounts above this being taxable, collected by the employer. (Section 50)
Sale of main home: Section 51 provides that profits from selling a primary residence are fully exempt, but this exemption is available only once per lifetime.
Takeaway:
The new rules broaden the scope of taxable assets, provide clear calculation methods, and introduce meaningful exemptions that protect small investors, employees receiving compensation, and homeowners selling their primary residence. These reforms make the tax system more transparent, equitable, and adapted to modern financial realities.
Part 9: The Tax Rates
The Nigeria Tax Act, 2025 introduces updated tax rates for companies and individuals, including new rules to ensure fairness and prevent tax avoidance.
Section 56: Tax Rates for Companies
Small Companies: 0% – a major incentive to support small businesses.
New Exemption Thresholds:
Small companies are now exempt from Companies Income Tax (CIT), Capital Gains Tax (CGT), and the newly introduced Development Levy.
Definition of Small Company:
Annual gross turnover of ₦100 million or less (previously ₦25 million)
Total fixed assets not exceeding ₦250 million
All Other Companies: 30% – the standard corporate tax rate for medium and large businesses.
Section 57: Minimum Effective Tax Rate for Large Companies (New)
Rule: Large companies (turnover of ₦3 billion and above) or multinationals that reduce their effective tax rate below 15% through deductions must pay an additional tax to reach the 15% minimum.
Purpose: Prevents large companies from reporting large profits while paying minimal tax in Nigeria using aggressive accounting strategies.
Section 58: Tax Rates for Individuals
Individual tax rates are found in the Fourth Schedule of the Act.
These follow a progressive band system, e.g., 7% on the first ₦300,000, 11% on the next band, and so on.
Key Takeaway:
The Act provides support for small businesses, maintains standard corporate rates, and introduces minimum taxation rules for large companies to ensure fairness, while individuals are taxed under a progressive system to reflect their earnings.
Chapter 3: Petroleum Taxation – A New Dual Regime
The Nigeria Tax Act, 2025 fully modernizes petroleum taxation, aligning it with the Petroleum Industry Act (PIA) 2021 framework.
Key Features:
Hydrocarbon Tax (HT):
Replaces the old Petroleum Profits Tax (PPT) for upstream operations.
Applies only to crude oil and liquids from associated gas, excluding natural gas, to incentivize gas development.
Rates:
30% for onshore and shallow water Petroleum Prospecting Licences (PPLs)
15% for similar Petroleum Mining Licences (PMLs) and deep offshore operations
Companies Income Tax (CIT):
Upstream petroleum operations remain subject to standard CIT under Chapter 2.
HT is not deductible for CIT purposes.
Gas Incentives:
Tax credits and allowances for Non-Associated Gas (NAG) greenfield projects, especially those with low liquid content, encourage investment in the gas sector.
Production Sharing Contracts (PSCs):
Governs Deep Offshore and Inland Basin PSCs that have not converted under the PIA, with a specific tax rate of 50%.
Takeaway:
This dual regime separates hydrocarbon taxation from regular CIT while offering incentives to promote gas development and foreign investment in Nigeria’s energy sector.
Chapters 5 & 6: Transaction-Based Taxes (Stamp Duties & VAT)
A. Stamp Duties (Chapter 5)
Modernized Administration:
Supports electronic denotation of duty (e-stamping) for faster, more efficient processing.
Exemptions:
Electronic transfers below ₦10,000
Salary payments
Intra-bank transfers
Clearer Base:
Detailed definitions of chargeable instruments, including:
Conveyances
Leases
Share capital
Loan capital
B. Value Added Tax (VAT) (Chapter 6)
The Nigeria Tax Act, 2025 modernizes the VAT system, expanding coverage, improving compliance, and aligning with global standards, particularly for digital services. The VAT rate is retained at 7.5%, while place of supply rules clarifies when goods or services are considered supplied in Nigeria, ensuring digital and cross-border transactions are properly taxed.
Non-resident suppliers are now required to register for VAT, with mechanisms for either collecting the tax directly or having the Nigerian recipient self-account. The Act revises exemptions and zero-rated supplies, covering essential goods and services such as basic food items, medical products, educational materials, electricity, and certain exports. Importantly, businesses can now recover input VAT on purchases and fixed assets related to VAT-liable supplies, including zero-rated items, reducing the effective tax burden.
Nigeria also introduces fiscalisation rules and mandatory e-invoicing, making it one of the early adopters of digital VAT administration in Africa, enhancing efficiency and compliance. Additionally, the VAT revenue-sharing formula has been updated: the Federal Government receives 10%, while States and Local Governments receive 55% and 35%, respectively, with allocations based on equality, population, and place of consumption.
Impact: These reforms modernize VAT collection, ensure fairness in revenue distribution, improve business compliance, and strengthen the capture of taxes from the digital economy while keeping essential goods and services accessible.
6. New Taxes & Levies
The Nigeria Tax Act, 2025 introduces two notable new levies to support strategic national funds and promote environmental accountability:
Development Levy (Section 59):
Nigerian companies, except small companies, are required to pay a 4% levy on assessable profits (i.e., profits before deducting tax depreciation and losses). This levy consolidates several previous levies, including:
Tertiary Education Tax (TETFund)
Information Technology Levy (IT)
National Agency for Science and Engineering Infrastructure (NASENI) levy
Police Trust Fund (PTF) levy
The collected revenue is earmarked for specific purposes:
Tertiary Education Trust Fund (TET Fund): 50%
Nigerian Education Loan: 15%
National Cybersecurity Fund: 5%
Other agencies (e.g., NITDA, NASENI)
Surcharge (Chapter 7):
A 5% surcharge on fossil fuel products, designed as an environmental tax, with exemptions for clean energy, household kerosene, and cooking gas.
Impact: These levies broaden the tax base, fund critical national priorities such as education, technology, and security, and incentivize environmentally friendly energy use.
7. Chapter 8: Tax Incentives – A Reformed System
The Act streamlines and centralizes tax incentives to promote investment, job creation, and economic growth:
Economic Development Tax Incentive: Replaces the Pioneer Status regime. Administered by the Nigerian Investment Promotion Commission (NIPC), it provides a tax credit equal to the tax payable on profits from “priority products” for five years.
Specific Exemptions: Certain types of income are exempt, including:
Profits of agricultural businesses for the first five years
Gains from the disposal of assets by venture capitalists in qualifying startups held for 24 months or more
Dividends from wholly export-oriented businesses
Income of minimum wage earners
Wage & Job Creation Incentive: Businesses receive a 50% additional deduction for wages paid to low-income workers and salaries of new employees (net increase) for 2023–2025, incentivizing employment growth.
8. Critical Administrative & Anti-Avoidance Provisions
The Act strengthens administration and anti-avoidance measures to ensure compliance:
General Anti-Abuse Rule (GAAR – Section 191): Allows the tax authority to disregard artificial or fictitious transactions aimed at tax avoidance and make adjustments as necessary.
Transfer Pricing (Section 192): Reinforces the arm’s length principle for transactions between related parties, empowering the tax authority to make adjustments in line with Transfer Pricing Regulations.
Business Restructuring (Section 190): Provides tax-neutral rules for mergers, acquisitions, and sales, giving certainty on tax consequences for corporate reorganizations.
Conflict of Laws (Section 201): Clarifies that the provisions of the Act prevail over any inconsistent law concerning the imposition and administration of taxes.
Impact: These reforms simplify incentives, promote investment and employment, and strengthen compliance mechanisms while reducing opportunities for tax avoidance.
9. Free Trade Zone and Investment Incentives
The Nigeria Tax Act, 2025 maintains tax incentives for Free Trade Zone (FTZ) entities while introducing some restrictions:
Tax Exemption on Exports: Profits from exports or output used in goods/services ultimately exported, or supplied to oil and gas companies, remain fully tax-exempt.
Sales to Domestic Market: If more than 25% of turnover is made within the Nigerian customs territory, proportionate taxes now apply.
From 1 January 2028, all profits from domestic sales by Free Zone entities will be fully taxable.
Impact: These rules encourage export-oriented business activities and investment in agriculture and employment, while gradually bringing domestic sales of FTZ entities under regular tax rules.
The Nigerian Tax Administration Act (NTAA)
The Nigerian Tax Administration Act (“NTAA”) establishes a uniform legal and administrative framework for the effective, consistent, and transparent administration of the Nigerian tax system. The primary objective of the NTAA is to facilitate voluntary tax compliance, enhance administrative efficiency, and optimise the mobilisation of tax revenue for the Federation.
1. Mandatory Taxpayer Identification Number (TIN) Registration
Pursuant to the provisions of the NTAA, every taxable person—including individuals, Ministries, Departments and Agencies (“MDAs”) of the Federal, State, and Local Governments—is under a statutory obligation to register for tax purposes and obtain a Taxpayer Identification Number (TIN).
In addition, non-resident persons who make taxable supplies to individuals in Nigeria or derive income from Nigeria (other than passive income from investments) are similarly required to register for tax purposes and obtain a TIN.
Furthermore, any person or entity engaged in the provision of financial services shall ensure that every taxable person to whom such services are provided furnishes a valid TIN as a condition precedent to the consummation of the relevant transaction.
The TIN requirement is designed to ensure comprehensive identification of all taxable persons, including those operating within the informal sector, and to strengthen the integrity of the tax system by mitigating tax evasion and avoidance.
2. Monthly Return Requirement
The NTAA prescribes specific obligations with respect to the filing of returns by taxable persons, including individuals and corporate entities. In particular:
Petroleum companies are required to submit returns in respect of royalty payments not later than the 14th day of the month following the month to which the payment relates;
Mining companies and non-resident shipping or airline companies shall submit their respective returns not later than the 21st day of the month following the month to which the return relates; and
Petroleum licence holders are further obligated to file annual returns detailing all royalties paid during the relevant accounting period within five (5) months after the end of such accounting period.
These statutory timelines are intended to ensure prompt and accurate reporting, enhance fiscal transparency, and promote accountability in the administration of tax obligations under the NTAA.
3. Digitalisation of Tax Filing and Compliance
A notable innovation introduced under the NTAA is the establishment of the Electronic Fiscal System (EFS). The EFS is designed to enhance the accuracy, efficiency, and transparency of tax administration through digital processes.
Pursuant to the provisions of the NTAA, all taxable persons are required to maintain accurate and up-to-date records of all transactions processed through the EFS. The institutionalisation of electronic tax filing constitutes one of the most significant reforms under the Act, as it seeks to minimise human intervention and, by extension, reduce the incidence of errors, fraud, and administrative inefficiencies within the tax system.
The introduction of the EFS underscores the critical importance of digitalisation in modern tax administration and represents a decisive step toward achieving enhanced compliance, greater operational efficiency, and improved transparency in Nigeria’s tax regime.
4. Filing of Returns by Virtual Asset Service Providers (VASPs)
In line with the statutory recognition of virtual assets under Nigerian law, the NTAA imposes an obligation on all taxable persons engaged in activities relating to the exchange, custody, or management of virtual assets through Virtual Asset Service Providers (VASPs) to duly file their tax returns in accordance with the provisions of the Act.
This obligation is without prejudice to the authority of the relevant tax body to demand such additional information or documentation as may be deemed necessary for the effective discharge of its statutory functions.
Any VASP that fails to comply with the filing requirements prescribed under the NTAA shall, in addition to the possible suspension or revocation of its licence by the Securities and Exchange Commission (SEC), be liable to an administrative penalty of ₦10,000,000 (Ten Million Naira) for the first month of default and ₦1,000,000 (One Million Naira) for each subsequent month during which the default continues.
These provisions reinforce the Federal Government’s commitment to ensuring that emerging digital financial activities, including virtual asset transactions, are brought within the formal tax framework, thereby promoting fairness, accountability, and comprehensive revenue mobilisation.
5. Transaction Threshold Reporting
Pursuant to the provisions of the NTAA, banks and other financial institutions are mandated to submit quarterly returns to the relevant tax authority detailing:
all new customer accounts opened within the reporting period; and
for existing customers, all individual transactions exceeding ₦25,000,000 (Twenty-Five Million Naira) and corporate transactions exceeding ₦100,000,000 (One Hundred Million Naira) on a monthly basis.
This reporting obligation is intended to strengthen the transparency and traceability of high-value financial transactions, facilitate the identification of taxable persons and income flows, and assist the tax authorities in combating tax evasion, illicit financial flows, and other related malpractices.
6. Revised VAT Sharing Formula
Section 81 of the NTAA introduces a revised Value Added Tax (VAT) distribution formula among the three tiers of government as follows:
Federal Government: 10%
State Governments: 55%
Local Governments: 35%
Furthermore, the portion of VAT revenue standing to the credit of State and Local Governments shall be distributed on the following basis:
Equality: 50%
Population: 20%
Place of Consumption: 30%
This revised allocation framework reflects a deliberate policy shift towards ensuring equity and fairness in the administration and distribution of VAT revenue, while recognising the relative contributions and consumption patterns across the various subnational entities.
The Nigeria Revenue Service (Establishment) Act
The Nigeria Revenue Service (Establishment) Act (the “NRS Act”) establishes the legal, institutional, and regulatory framework for the administration, collection, and management of all revenues accruable to the Federal Government of Nigeria.
Pursuant to the provisions of the NRS Act, the Nigeria Revenue Service (the “Service”) is hereby established as the principal authority responsible for the administration of federal taxes and related revenue matters. The Service assumes all statutory functions, powers, rights, and obligations previously vested in the Federal Inland Revenue Service (“FIRS”), thereby effecting a complete institutional transition and continuity of tax administration at the federal level.
The NRS Act further empowers the Service to assess, collect, and account for all revenues accruable to the Federation, and to perform all incidental functions connected thereto. In addition, the Service may, upon request, assist any State Government, the Federal Capital Territory (FCT), or Local Government Council in the collection or administration of any tax which such requesting authority is lawfully empowered to impose and collect. Such assistance may, however, be subject to the payment of a service fee designed to defray the administrative costs incurred in providing such assistance.
By virtue of the enactment of the NRS Act, the Service now serves as the primary regulatory and administrative body for all federal tax matters in Nigeria, ensuring uniformity, accountability, and efficiency in the implementation of national tax policy and revenue administration.
Joint Revenue Board Nigeria (Establishment) Act, 2025
The objectives of the JRB Act include:
The provision of a legal and institutional framework for the harmonisation and coordination of revenue administration across the Federation;
The establishment of an effective mechanism for the resolution of inter-jurisdictional tax disputes; and
The promotion and protection of taxpayers’ rights within the Nigerian tax system.
The JRB Act formally establishes the Joint Revenue Board Nigeria (the “Board”) as a statutory body responsible for fostering cooperation and coordination among federal, state, and local tax authorities. The Board is mandated to ensure policy alignment, reduce administrative duplication, and enhance the overall integrity and efficiency of the national tax administration framework.
Key Highlights and Implications
Institutional Harmonisation and Coordination
The enactment of the NRS Act and the JRB Act collectively signifies a decisive move toward a unified and coherent tax administration structure in Nigeria. While the NRS Act centralises federal tax administration under the Nigeria Revenue Service, the JRB Act establishes a collaborative mechanism to align federal and subnational tax operations, thereby minimising conflicts of jurisdiction and overlapping mandates.
Enhanced Revenue Efficiency and Transparency
The framework introduced under both Acts is designed to streamline revenue collection, enhance data sharing and inter-agency collaboration, and promote fiscal transparency across all tiers of government. This is expected to improve revenue mobilisation and reduce revenue leakages.
Dispute Resolution and Taxpayer Protection
The JRB Act introduces a structured dispute resolution mechanism aimed at addressing conflicts arising between tax authorities or between taxpayers and revenue agencies. In addition, it reinforces the protection of taxpayer rights, including fairness, due process, and access to redress mechanisms.
Strengthened Federal–State–Local Government Cooperation
By empowering the Nigeria Revenue Service to assist states and local governments under the NRS Act, and by establishing the Joint Revenue Board as a coordinating entity under the JRB Act, the reforms collectively foster a more collaborative fiscal relationship among the various tiers of government. This cooperative approach is essential for ensuring consistency in tax policy implementation and national economic development.
Institutional Continuity and Reform Sustainability
The Acts together establish a modernised tax administration architecture, ensuring that institutional reforms initiated under the Federal Inland Revenue Service are not only sustained but expanded in scope and effectiveness through clearer statutory mandates and improved governance mechanisms.
Conclusion
The enactment of the new Tax Laws represents a deliberate and progressive effort toward establishing a fair, transparent, and growth-oriented tax system in Nigeria. The harmonisation of the country’s historically fragmented tax landscape—coupled with the integration of digitalisation and modern compliance mechanisms—constitutes one of the most innovative features of the reform framework.
However, the successful implementation of these laws will depend substantially on:
The attainment of judicial clarity with respect to potential constitutional questions; and
The development of robust administrative and technological infrastructure at both the federal and subnational levels.
In light of these reforms, it is imperative for both individuals and corporate entities to proactively evaluate and strengthen their tax governance frameworks. Specifically, taxpayers are advised to:
Get informed – Develop a clear understanding of the specific provisions of the new tax laws that apply to their operations and ensure proper sensitisation of management and key decision-makers;
Maintain accurate records – Establish and continuously update a tax risk register, enhance internal record-keeping systems, and align compliance processes with the new regulatory requirements;
Conduct a holistic impact assessment – Review operational, financial, and compliance implications arising from the new tax regime;
Consult qualified tax professionals – Seek expert advice to ensure proper interpretation of the laws and mitigate exposure to penalties or disputes; and
Plan for compliance – Develop a forward-looking compliance strategy that embeds adaptability and responsiveness to evolving regulatory expectations.
Ultimately, the new tax laws provide an opportunity to restore investor confidence, broaden the revenue base, and channel critical resources toward sectors essential for sustainable national development. With effective implementation, institutional cooperation, and taxpayer readiness, these reforms could mark a transformative milestone in Nigeria’s fiscal governance landscape.
Authors and Editor
Authors:
A.U Opara Esq.
NYSC, Associate
Pillar-Rest Attorneys
A Nigerian lawyer with a focus on corporate and commercial law. She is passionate about simplifying complex legal and regulatory frameworks for businesses and individuals. Her work focuses on bridging the gap between the law and practical business realities, empowering clients to make informed decisions with confidence.
Russell Yilchir Gerlong
Head of Intellectual Property
Pillar-Rest Attorneys
Rusell Y Gerlong is a Nigerian legal practitioner passionate about intellectual property, technology, and startups. He combines legal expertise with creative insight to drive innovation, support emerging ventures, and foster social impact.
Uwazie Obinna Emmanuel
Head of Litigation
Pillar-Rest Attorneys
A dedicated legal practitioner who represents clients with precision, integrity, and a steadfast commitment to justice. Renowned for his expertise in litigation, he adopts a strategic and results-oriented approach to navigating complex legal matters.
Patience Yusuf Odeniya Esq
Legal Consultant
Pillar-Rest Attorney
She is a legal consultant with broad experiences spanning corporate restricting, regulatory compliance, legal research, and multiple areas of law. She has a strong aptitude for policy drafting and advisory work and has contributed significantly to advancing the firm’s strategic and legal objectives through clear, practical and well-reasoned analysis.
Editor
Serving dually as an Author and the Editor of this publication, Patience Yusuf Odeniya Esq leads the policy research and editorial review process.
