By Musa Ibrahim
The federal government has opened a six-week review of Nigeria’s new tax laws, responding to implementation challenges and concerns raised by businesses, while maintaining that the exercise is aimed at improving the reforms rather than reversing them.
The Honourable Minister of Finance and Coordinating Minister of the Economy, Mr. Taiwo Oyedele, recently announced the review in Abuja while inaugurating the Technical Subcommittee on Fiscal Policy and Tax Reforms.
The review comes months after the Nigeria Tax Act 2025, Nigeria Tax Administration Act 2025, Nigeria Revenue Service (Establishment) Act 2025 and Joint Revenue Board (Establishment) Act 2025 took effect on January 1, 2026.
Mr. Oyedele said the transition from legislation to implementation had exposed areas requiring clarification, refinement and further reform.
“The real test begins when the law meets the economy, as businesses interpret it, administrators implement it, investors respond to it, and citizens experience it,” he said.
The subcommittee will examine issues including Value Added Tax (VAT) thresholds, withholding tax, capital gains treatment and multiple taxation. Its mandate will also extend to fiscal policy and management, public financial management, debt, transparency, capital markets and cross-border capital flows.
The review follows growing concerns from the organised private sector over how some provisions of the new framework are being interpreted and administered.
Recall in June, the Manufacturers Association of Nigeria (MAN), Nigerian Association of Small and Medium Enterprises, Nigerian Association of Small-Scale Industrialists, Nigerian Association of Chambers of Commerce, Industry, Mines and Agriculture and Nigeria Employers’ Consultative Association jointly wrote an open letter to President Bola Tinubu.
The groups said conflicting interpretations of the new laws had created uncertainty around corporate tax filings. They stressed that their intervention was not opposition to tax reform or lawful revenue mobilisation.
“This Open Letter is not an attack on tax reform or lawful revenue mobilisation,” the groups stated, stating that businesses wanted “a clear, lawful and functional framework” through which they could file returns, meet tax obligations, protect jobs and continue investing.
A major point of contention is the treatment of tax obligations arising from accounting periods that ended before January 1, 2026.
The private sector groups relied on the General Transition Guidelines issued pursuant to the new tax legislation, which provide that obligations arising from accounting periods ending before the commencement of the new laws should continue to be governed by the repealed laws, even where filing or payment falls due after January 1, 2026.
The groups, however, alleged that the Nigeria Revenue Service (NRS) had adopted a different interpretation.
The issue became more pronounced after the NRS Emerging Taxpayers Office in Abuja issued a June 23 notice directing companies that had not filed their Companies Income Tax (CIT) returns for the 2026 Year of Assessment to do so under the new framework.
The NRS stated that its authority to process the returns was determined by statute rather than taxpayer choice and said it had no authority to process them under repealed legislation.
The dispute has placed implementation clarity at the centre of the latest review.
Mr. Oyedele said the government was now moving from fundamental tax reform to continuous improvement, with the proposed Finance Bill 2027 serving as a vehicle for addressing issues identified during implementation.
“The Finance Bill 2027 should not be seen as just another annual legislative exercise. Our task is not to rewrite the 2025 reforms, but to preserve their fundamental principles while learning from implementation and responding to new economic realities.”
The review is also being shaped by submissions from businesses and other stakeholders. Mr. Oyedele said 134 submissions were received from across Nigeria’s geopolitical zones following a public invitation for input, with additional submissions made in hard copy.
Stakeholders also called for greater digitalisation and data sharing so taxpayers do not repeatedly submit information already held by government agencies. Other recommendations cover taxpayer rights, faster refunds and safeguards for small businesses.
Mr. Oyedele instructed the subcommittee to assess the wider economic consequences of proposed changes, particularly their effects on households, workers and businesses.
“Every tax reform produces winners and losers; the question is whether a policy is fair, efficient and competitive, not whether it is popular with everyone,” he said.
The committee will also review the Deduction of Tax at Source Regulations 2024 and prepare revised withholding tax regulations. It will examine the Companies Income Tax (Significant Economic Presence) Order 2020 and develop an updated framework aligned with the new tax laws and international practices.
The subcommittee is chaired by the Permanent Secretary of the Federal Ministry of Finance, with Tax Advisory Committee Chairman Albert Folorunsho serving as co-chair. Its membership includes representatives of government agencies, business groups, professional bodies and the Big Four accounting firms.
The review consequently places the first year of the new tax regime under scrutiny, with the government seeking to preserve the architecture of the 2025 reforms while resolving ambiguities that have emerged in actual application.
