THE NIGERIA TAX ACT 2025: A CRITICAL EXAMINATION OF CONSOLIDATION, IMPLEMENTATION CHALLENGES, AND INSTITUTIONAL IDENTITY CRISIS.
THE NIGERIA TAX ACT 2025:

A CRITICAL EXAMINATION OF CONSOLIDATION, IMPLEMENTATION CHALLENGES, AND INSTITUTIONAL IDENTITY CRISIS.

Abstract

The Nigeria Tax Act (NTA) 2025 is the most significant legislative change to the Nigerian income tax environment since the return to democracy. By consolidating an array of statutes - inclusive of the Companies Income Tax Act (CITA), Capital Gains Tax Act, and various other state levies - to make it less complex for compliance, the NTA 2025 represents an attempt to modernize revenue administration. Central to the government metrics (NTA 2025) is the 'Single-Digit Ambition', a policy goal that will ultimately look to convert the multitude of taxes into a manageable number of taxes, in order to improve 'ease of doing business' metrics. Additionally, the NTA 2025 brings Nigeria in-line with OECD norms, through the OECD Pillar Two framework, by providing for a minimum effective tax rate (ETR) of 15% for large businesses.

This article creates a critical appraisal of the NTA 2025, by identifying structural 'glitches' that demonstrated a disconnect from Nigerian reality. For example, the (NGN500,000) rent relief cap was simply insufficient for property in higher rental zones, the excessive limitations on forex deductions during liquidity shocks were likely punitive, and lastly, the 'guilt by association' clause in respect of Value Added Tax (VAT) compliance. Next, I will critique the centralization of the investment certification for in-country investments within the NRS, as an institutional identity crisis, that if operationalized would prioritize short-term extraction of taxes revenues over a longer-term attraction of industrial investments to Nigeria. My intention through this review is to be decisively benchmark the justified acclaim for legislative coherence, whilst at the same time provide a sober assessment of the implementation issues for tax-payers and authorities.

  1. INTRODUCTION

The NTA 2025 and the Nigeria Tax Administration Act (NTAA) mark a significant chapter in Nigeria's economic history. Nigeria had a 'legal junk drawer' model of tax system for at least thirty years, introducing levy after levy on previous tax statutes to layer upon the administrative noise with new statutory obligations over a protracted period with nil improvement to the investment environment.

The 2025 reforms passed by the National Assembly and codified will introduce a new, modern tax code that replaces the prior chaos with streamlined legislation. The goal is to create a fiscal environment that is predictable for investors and efficient for the state.

More broadly, the NTA 2025 is an attempt to synchronize domestic law with the rapidly changing global digital economy. As digital services and virtual assets increasingly drive Nigerian commerce, the prior tax regime had become difficult if not impossible to apply in a regime unable to capture value arising from borderless transactions [id12]. The intent of the NTA 2025 in relation to digital assets and 'fiscalizing' supplies, is sustain the traditional tax base whilst taxing and broadening the tax base without increasing overall tax base tax compliance for ordinary citizens. Finally, the reforms are a response to the "Igbo Question" and other agitating regional socio-economic grievances whereby equitable collection of revenue and its equitable distribution is a precondition for stabilizing the country's equilibrium. While these are noble objectives, the practical and philosophical hurdles to actualization will be immense. The reform initiative brings a core orientation shift in the management of investment incentives from a long-standing Pioneer Status Incentive (PSI) to a performance-based Economic Development Tax Incentive (EDTI). This shift has already ignited debates about the role of the National Revenue Service (NRS) when there are agencies principally dealing with investments like the Nigeria Investment Promotion Commission (NIPC), the Nigerian Oil and Gas Free Zones Authority (OGFZA) and the Nigeria Export Processing Zones Authority (NEPZA). The conjecture voiced is that the mere accumulation of authority within the revenue authority is already an issue of conflict of interest, where the agency that has the compelling directive to maximize collections is also the gate-keeper for applicable tax reliefs.

This paper aims to provide a full consideration of these matters. In section 2 we review the parts of the consolidation that went well and the global alignment. Section 3 discusses the "glitches in the matrix," in the form of the significant provisions where legislative intent is inconsistent with economic reality. Section 4 covers the institutional friction created by the centralization of the investment policy, while Section 5 tracks this conceptual path of the prospective implementation as it relates to SMEs and digital-native firms. Ultimately, we propose a "refined" approach to the matter, where legislative coherence is upheld, and the authority of the specialized investment agencies is re-established.

  1. THE BRIGHT SIDE: COMMENDING THE MERITS OF TAX CONSOLIDATION.

In many ways, the NTA 2025 is a legislative accomplishment of organization over disorganization. By repealing and consolidating more than a dozen individual tax laws, the Act deals with the long-existing "compliance fatigue" of the Nigerian private sector. This section considers the positive implications of that consolidation, the rush toward a single digit tax regime, and the importance of being internationally regarded.

2.1  From Legislative Chaos to Coherence: Repeal of Overlapping Provisions

Prior to 2025, a Nigerian company would remain in near exile with the exotic assortment of statutes, whether Companies Income Tax Act, or Petroleum Profits Tax Act, or Education Tax Act, and other Sector specific levies - including the NASENI and NITDA levies. The messy landscape of tax provisions created administrative burdens, because the business would have to calculate tax obligations based on different due dates, methodologies for calculations, and dispute resolution for multiple agencies. The NTA 2025 represents a "Marie Kondo" conditioning of the tax law by removing overlapping provisions, and replacing them with one document that is internally consistent.

Repeal of these miscellaneous laws is more than a clerical exercise. It represents a complete systemic disposition toward a "Single Window" for fiscal policy. In the new fiscal regime, we will find a common framework for taxable income, deductible expenses, and capital allowances - across sectors reducing the opportunity for ambiguity, and the attendant litigation that follows curiosity about what is actually meant when legislated. The orientation to coherence should reduce cost of compliance for businesses, and lower cost of collection for government, creating a more efficient fiscal system where operations are not hindered by bureaucratic navigation and thus allow for productive economic activity.

2.2 The Single-Digit Ambition: Abolishing nuisance taxes and organizing revenue generation

One of the apparent most daunting goals of the 2025 reform is to have the total number of taxes in Nigeria reach a "single digit". Historically, elimination of "nuisance taxes" - which are mostly small, site-specific taxes collected that generate little revenue but disrupt trade has been a significant deterrent to the Ease of Doing Business. The NTA 2025 intends to abolish nuisance taxes, by organizing other social and developmental levies - into a singular "Development Levy". The push for a single digit tax regime is based on the evidence that simplified tax regimes tend to have a better rate of voluntary compliance. When tax compliance is easy to understand and there are fewer payment points for taxpayers, the incentive to risk tax evasion is diminished. The convergence of the Tertiary Education Tax, the levy owed to the National Agency for Science and Engineering Infrastructure (NASENI) and the levy for the National Information Technology Development Agency (NITDA) into a single 4% Development levy is a practical application of type of simplification. For some corporation this may result in a larger tax base, however the decrease in administrative burden is a net benefit for the corporate sector.

2.3 Global Alignment: Pillar 2 & Modernizing Effective Tax Rate

Given the globalization of capital Nigeria can ill-afford to be a fiscal island. The NTA 2025 aligns Nigeria's tax system to specifically comply with the OECD/G20 Inclusive Framework of Base Erosion and Profit Shifting (BEPS), namely the rules of the Pillars Two model. The most significant change is the introduction of a minimum 15% Effective Tax Rate (ETR) for Multinational Enterprises (MNEs) with a group turnover exceeding €750 million Euro. The benefit of adopting these rules is that Nigeria can impose "top-up taxes" on profits taking place in Nigeria that may have previously eroded the tax base through movement to lower tax jurisdictions.

More importantly, NTA 2025 localizes the application of these rules by establishing the threshold for the application of the 15% ETR on large Nigerian companies at a domestic turnover of NGN 50 billion. This guarantees that the largest players in Nigeria contribute their fair share of tax but remain competitive with their global counterparts. The adoption of a 15% ETR is a departure from the "race to the bottom" tax competition, where countries are willing to provide excessive tax holidays or incentives to gain investment. The NTA 2025 now signifies the end of the "race to the bottom" model and offers hope for a new "race for the top" model, where a stable, transparent tax regime that aligns with international principles attracts high quality capital.

  1. GLITCHES IN THE MATRIX: INHERENT MISTAKES AND ECONOMIC DISCONNECTS

Despite the legislative elegance of simplification, the NTA 2025 contains several clauses that seem disconnected to the actual lived economic realities of individuals and businesses in Nigeria. These "glitches" risk undermining the objectives of the Act by imposing impractical compliance. and potentially punitive conditions on common sense commercial activity.

3.1 The Rent Relief Paradox: Measuring Urban Real Estate with a Thimble

Perhaps the most criticized clause in the new Act is the limit on relief for individual taxpayers. The Act decrees that taxpayers will be allowed to deduct rental expenses capped at NGN 500,000 per annum. Considering Nigeria's primary economic hubs, including Lagos, Abuja and Port Harcourt, this figure is embarrassingly low. Given the inflationary and devaluationary pressures on property values, NGN 500,000 per annum is a drop in the bucket versus the actual rent expense of most average urban professionals and small business owners. The "Rent Relief Paradox" is emblematic of a failure to properly index tax benefits to inflationary realities. By establishing fixed, static, and extremely low thresholds, the government progresses towards a "decorative doormat" as opposed to a safety net. For many taxpayers, the time and effort needed to collect documentation and submit for relief expenses may outweigh the aggregate tax savings. In fact, the policy may simply be emblematic of the purpose in theory, as it allocates benefits to persons above the threshold because it available to them, while providing no tangible benefit in the real world. Rent Relief, like other costs, would actually better serve the purpose in a meaningfully inflationary environment if tied to something regional like averages or a minimum wage.

3.2 The Forex Fiasco: Penalizing Businesses for Macroeconomic Liquidity Shortages

Section 20(4) of the NTA 2025 creates incredible administrative burdens on businesses in Nigeria's perpetual volatile forex market. Under this provision, the Act prohibits the deduction on a business's losses and expenses related to forex abstinence, often having to be calculated at the official exchange rate determined by the CBN. The dysfunction of the Nigerian market is the perpetual liquidity scarcity at the official window, which forces many businesses into alternative or parallel markets to source the required forex at a massive premium.

The Act is imposing a "Double Jeopardy" tax assessment, creating a situation where businesses cannot deduct the measure of the actual forex cost to conduct normal business operations, such as importing raw materials or servicing foreign debt. The Act implicitly requires taxpayers to conduct puthy business without any measure of expense deduction, which creates a "Forex Fiasco" scenario, where profit margins shrink to a depressing state for manufacturing and service industries. Many businesses will ultimately choose to create capital flight in search of a more realistic fiscal environment.

3.3  Guilt by Association: Denying Deductions for Third-Party VAT Compliance Failures

Coming behind the "guilt by association" progeny with the VAT compliance, is likely the most unpopular provision in the NTA 2025. Specifically addressed in Section 21(p), a business may have an expense denied deduction solely if their supplier failed to charge for VAT or remit the associated charge to the NRS. Simply put, every corporate accounting department in Nigeria, would now need to act as a full-time private contractor, evaluating their entire supply chain for compliance.

The government needs to be concerned with fundamental injustice of this policy. A compliant taxpayer is penalized for the limitations of third parties, over whom they and their process have no legal right. In a complex economy, that is entirely unrealistic to construct evidence that every vendor from large utility providers to landscape or janitorial service contractors, are in good standing with their respective tax collections. The obvious unintended consequence is that the government has implemented a compliance rule that would impact domestic supply chains, because larger firms will have to limit or refuse the business with SMEs that cannot provide ironclad proof that these were remitted to the government.

Rather than outsourcing the enforcement responsibility to the private sector, the NRS, in its modernized digital capabilities, should simply track and penalize those suppliers directly, as they are already remitting tax. The NTA 2025 is a big leap toward regulating fiscal affairs, but these embedded mistakes suggest that the "landing" of the reform will be bumpy for the Nigerian economy. The Alliance for Economic Research and Ethics supports periodic reviews of these particular provisions to ensure that the law enables rather than stifles the businesses that it seeks to regulate. The spirit of consolidation must be matched with the spirit of economic realism if the Nigeria Tax Act of 2025 is to reach its transformative potential.

  1. THE INSTITUTIONAL IDENTITY CRISIS: EVALUATING THE TAKEOVER OF INVESTMENT LAWS

The Nigeria Tax Act (NTA) 2025 brings significant changes to Nigeria's fiscal architecture, most notably, the establishment of the Nigeria Revenue Service (NRS) as the successor to the Federal Inland Revenue Service. While there appears to be rebranding in the service used to administer taxes, the legislation suggests an expansion of the mandate of the revenue authority into investment policy. The growth of power is an institutional identity crisis where the primary purpose of revenue extraction is likely to eclipse the nuanced task of attracting investment. Historically, investment incentives were the responsibility of specialized agencies who were better positioned to assess fiscal costs against long term economic benefits; the NTA 2025 crops up the center of gravity of incentives into a single revenue authority. The risk is a transformation of the fiscal ecosystem into a "Procrustean Bed" within which an investment policy must fit the prescriptive demands of generating revenue immediately.

4.1 The Revenue Service as Gatekeeper: Centralizing Investment Certification

The NRS will act as the primary gatekeeper of investment certifications; this goes against the collaborative model of fiscal governance we've had until now. The NRS has been granted wide powers to certify Qualifying Capital Expenditure (QCE); the process for review and approval was more decentralized. The structural change of the NRS implementing revenue extraction may materially conflict with the ability to grant incentives needed to attract capital; a tax collector has institutional DNA that optimizes for extraction. The Act requires that the NRS can grant a certificate within a 14-day window for granting revenue exemptions. However, since the Act lacks a "deemed approval" clause the 14-day window is a proverbial "toothless tiger" of a requirement. Without "deemed approval" investors are left exposed to a bureaucratic clock that could ultimately limit the growth the Act is designed to incentivize.

In addition, the NRS will be the final authority on the eligibility of a variety of tax credits and incentives, dislodging the original technical evaluations from industry-specific people that were involved in the prior models of approving investments. The "Single Window" of power of the NRS is significant and more indicative of the lens of taxation as the primary means the Nigerian state would use to look at economic development. The concern for the NRS may be the elimination of "tax leakages" rather than the more general goal of enabling large infrastructure projects. As the authority considers apportioning the tax base, it is possible that it has less scope on a strategic vision in an era of global tax competition.

4.2 Squaring the Circle: Why Economic Development Incentives (EDI) Work Best in Specialized Agencies

Economic Development Incentives (EDI) are the replacement for the outdated (and oft-criticized) Pioneer Status Incentive (PSI) and appear to be performance-based. However, identifying the certification and management of EDI within the tax administration framework is a case of "squaring the circle". Specialized agencies (such as the Nigeria Investment Promotion Commission (NIPC)) are better-suited to determine the "attraction DNA" that will lure international investors to Nigeria. These agencies understand the sectoral expertise that makes the investment opportunities operate in the Nigerian context; as key targeted investment areas, EDI is expected to benefit areas like agro-processing, renewable energy, and digital infrastructure.

The NTA 2025's pivot towards a 5% tax credit, while it is more fiscally conservative than a full tax holidays under the PSI, it may be too benign to be effective for capital intensive projects. These decisions about tax incentives would be best served by a centralized EDI board that has representatives from different economic sectors rather than be controlled by the revenue service. Once the revenue authority controls the tap for incentives, the emphasis will always be about the "cost" of the incentive rather than taking the time to maximize the "value" the incentive has for the national economy. This leads to the government "protecting" their tax base but losing the investments that would "grow" that tax base down the road.

4.3 Restoring the Mandate- The Case for NIPC, NEPZA, and OGZFA

To achieve a fair economic ecosystem, it will be important to restore the independent nature of specialized agencies like the NIPC, Nigeria Export Processing Zones Authority (NEPZA), and Oil and Gas Free Zones Authority (OGFZA). These entities were created with specific mandates to encourage regional integration and create domestic value chains. The NTA 2025's government redeployment of investment law provisions in a consolidated tax code runs the risk of distilling the difference between specialized knowledge and investor relationships developed over decades. Managing Free Trade Zones (FTZs) effectively requires deep and meaningful knowledge of customs territory and export logistics, which is disconnected from a traditional tax collector.

If we return the mandate to these specialized agencies, we will assure that, "vision" is different from the "mechanism" of tax collection. The global tax policy of "weaponized interdependence" can only be embraced if countries can be nimble in how they offer incentives to be competitive. If the NRS remains the sole designer of those policies, Nigeria may find itself in a position to quickly respond to the ever-evolving tactics of global corporations. If we decentralize these agencies to provide the certification, while the NRS manages the accounting, there will be a sense of checks and balances that does not put any one institution in a position where they are a "shadow sovereign" over the economy.

  1. THE IMPLEMENTATION MAZE- PRACTICAL HEADACHES FOR TAXPAYERS AND AUTHORITIES

The transition to the NTA 2025 is an overall "logistical" change not just a "legal" change presents an implementation maze for both the newly formed NRS and the Nigerian taxpayer. While the Act is promoting simplification, there are so many practical realities to consider, including digital asset valuations, automated invoices for SMEs and VAT refund management, which creates significant hurdles. All of these "glitches in the matrix" will most likely create additional compliance costs and administrative friction that may undermine the original intention of the Act to improve overall ease of doing business. As government wishes to modernize its revenue mobilization, it needs to be mindful of the "digital divide" and cash flow constraints, these new requirements will be put on the private sector.

5.1 Chasing Digital Ghosts- The Valuing and Tracking Challenges of Virtual Assets

One of the most ambitious aspects of the NTA 2025, the effort to bring virtual assets to the tax net with a 10% tax on the disposals of digital assets (Foye, 5554). However, the issue of valuing these assets is challenging due to price volatility and no central exchange in many cases (Arop, 4655). Investors risk being taxed on "phantom profits" that may not exist by the time the tax return is filed (UMENWEKE, 2025). The NRS has the challenge of tracking transactions using decentralized networks, a complex challenge requiring sophisticated tech infrastructure and international collaboration (Nwankwo, 2025).

Moreover, non resident suppliers (NRS) of digital services must register and remit taxes. This is in line with global standards, but actual enforcement of such provisions against "digital ghosts" without physical presence in Nigeria represents significant difficulty. Without a clear rule around valuation, and a mechanism to track, the taxation of digital assets could result in a wave of litigation around tax valuations and "unfairness" in light of generations of tech-savvy young professionals. The government must go beyond policy intent, and invest in digital payment tracking systems that make these provisions applicable.

5.2 The SME Tech Gap: Fiscalization Costs and Automated Invoicing

The NTA 2025 introduces "fiscalization of supplies", or requiring businesses to utilize Electronic Fiscal Systems (EFS) to report real-time reportable transactions to the NRS. This is a bold move to a modern context to mitigate tax avoidance. However, this will create a large "tech gap" for small and medium enterprises (SMEs). The cost of purchasing, integrating, and maintaining EFS systems may be unattainable for small businesses encumbered by exorbitant operating costs and limited access to credit. Unless the government plan to offer subsidies, the implementation and compliance with EFS could devolve into a technology tax that further squeezes smaller players into the informal economy.

Furthermore, automated invoicing can only be successful if a level of digital literacy and reliable internet connectivity exists evenly throughout the country. In many areas of Nigeria the infrastructure to support reporting for real-time fiscalization is lacking or unreliable and imposes an unfair advantage on at the taxpayer's expense in potential compliance failures. The "Integrated Tax Administration System" (ITAS) should be able to handle a data influx, without lag or frequent downtimes experienced by other digital initiatives. For an SME survivalist, EFS represents another layer of "compliance fatigue" in an already constrained environment of macroeconomic challenges.

5.3 The Refund Waiting Game: Cash Flow Friction in Zero-Rated Supply Chains.

The VAT refund mechanism under the NTA 2025 still presents a significant cash flow issue for the businesses involved in zero-rated supplies, i.e., exporters and some manufacturers. As a result of the zero-rated nature of their final supplies, these businesses utilize input supplies that have VAT embedded into their cost but they don’t charge VAT on their final output which leads to an infinite state of "input tax credit". The delay in the processing of these refunds turns the Government into a lender of interest-free loans from the private sector. In addition, in a high inflationary environment, the real value of funds that are in the "waiting room" of the tax authority reduces significantly the longer they are pending (Muyangwa, 2021).

The administrative burden of justifying the validity of refund claims leads to lengthy audits which further delay the funds being sent to the businesses. The inefficient use of time for refunds is particularly harmful for businesses in the mining and mineral value chains in Nigeria, as the ongoing capital requirements and cash flow are essential. To address business cash flow friction, the NRS should implement a more efficient and risk-based refund system to pay or refund established taxpayers that have a history of compliance. Without such process reforms, the "waiting game" for refunds will continue to be a hidden tax on Nigeria's most productive and export-based industries.

  1. CONCLUSION

The Nigeria Tax Act 2025 is a monumental reform representing the Nigerian Government's commitment to fiscal modernisation and revenue sustainability. Consolidating numerous tax laws into a single and cohesive framework represents a long-awaited opportunity to address legislative chaos and provide further clarity to both domestic and international investors. Along with the intent to achieve a "single digit" tax environment, aligning with global standards such as OECD Pillar 2 are important steps to make Nigeria a more competitive capital destination. But as this appraisal has sought to demonstrate, the probabilities for success in implementing represent significant institutional and practical challenges, which cannot be ignored.

Perhaps the greatest structural risk is the ambiguous "institutional identity crisis" deriving from the concentration of investment powers in the NRS. A single revenue service provides administrative efficiencies, but it cannot come at the risk of removing the focus agencies like the NIPC and NEPZA have in their specialized expertise or "attraction" mandates. The Government has to be careful that the "Cashier" for the State does not become the "Architect", since generating a budget are competing efforts with either a short-term revenue extraction focus versus long-term sustainable industrial growth. Key to economic reform success is providing balanced autonomy to investment promotion entities, while integrating them into a newly modernized fiscal framework.

Moreover, the "implementation maze" is another real risk towards successfully enacting the Act's objectives. The challenges of taxing digital assets, tech burdens to SMEs, and enduring friction in receiving VAT refunds, could all mitigate the "Marie Kondo" effect of tax law consolidation. If the NRS is unable to promote the "digital divide" and cash flow constraints from the private sector, the Act may end up increasing the cost of doing business and promoting non-compliance. As the Act promotes fiscalization of supplies and tax implications of virtual based assets, it will take more than just legal mandates, it requires a commitment to investing in technology, infrastructure, and human capital. In closing, the NTA 2025 is progressive, but it is progress that must be gently grounded. The Alliance for Economic Research and Ethics is clear that the flaws identified (for example, "forex fiction" in expense deductions and "guilt by association" in VAT compliance) are "not insurmountable." They are, however, "poltergeists" in the attic of the new tax code that must be eliminated through specific amendments, and realistic administrative principles. With a restored institutional balance, embracing macroeconomic reality, and acknowledging the technological transition of SMEs, Nigeria can refashion the NTA 2025 from a legal "junk drawer" into a uni-directional engine for economic prosperity, in summary, the outcome of this legal and administrative reform will be determined less by the number of repealed laws than the speed of economic activity generated. It is also crucial for policymakers to consider the experiences of other sectors in addressing similar challenges. For instance, the complexities encountered in Nigeria's pharmaceutical industry, as analyzed in a recent study, highlight the importance of finance and incentives in encouraging sectoral development. Learning from these challenges, the Nigeria Tax Act 2025 requires not only legal frameworks but also strategic financial incentives to support technology adoption and enhance compliance mechanisms.

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