An Overview of the Quadruplet Tax Laws in Nigeria

1. Introduction

In a landmark legislative overhaul in June 2025, Nigeria reformed its tax landscape. The reform built upon four interconnected laws, each with a distinct purpose: one that defines what is taxed; one that outlines how taxes are administered; one that establishes a new federal tax authority; and one that creates bodies for coordination and dispute resolution.

These acts, which I have collectively referred to as the “Quadruplet Tax Laws” within this article, aim to create a unified, modern, and efficient tax system. They are as follows:

The Nigeria Revenue Service (Establishment) Act, 2025
The Joint Revenue Board of Nigeria (Establishment) Act, 2025
The Nigeria Tax Administration Act, 2025
The Nigeria Tax Act, 2025

This article aims to provide an overview of each of these foundational laws and their implications to the overall Nigerian tax regime. In my subsequent articles pieces, I will explore the tax landscape for virtual assets and related transactions in Nigeria, providing insights into the applicable tax regimes. I will also outline the key compliance obligations for Virtual Asset Service Providers (VASPs) and discuss the potential penalties for non-compliance, offering a comprehensive overview of the regulatory requirements in this rapidly evolving space.

2. General Overview

2.1 The Nigeria Revenue Service (Establishment) Act (NRSA), 2025

The NRSA repeals the Federal Inland Revenue Service (FIRS) (Establishment) Act of 2007 and establishes a new primary federal tax authority called the Nigeria Revenue Service (NRS). The NRS is established as a body corporate with a perpetual succession and a common seal, capable of suing and being sued in its own name.¹ The Act’s main objective is to provide a legal and institutional framework for the administration of taxes and revenues that are due to the Nigerian government.²

The NRS is charged with the powers of assessment, collection of, and accounting for all revenues accruable to the Federal Government. Its primary functions include the following:

Assessing and collecting taxes from companies and other³ designated persons
Administering all revenues accruing to the Federal Government
Conducting examinations and investigations to enforce compliance with tax laws
Collaborating with other agencies to review tax regimes and promote economic development
Issuing Taxpayer Identification Numbers (TINs) in partnership with State authorities and the Joint Revenue Board⁴
Assisting any State, the Federal Capital Territory, or Local Government in administering or collecting a tax upon request

The NRS is supervised by a Governing Board⁵ composed of the Executive Chairman (who is the chief executive of the NRS), ex-officio members representing key government bodies like the Ministry of Finance, Central Bank of Nigeria, and the Nigeria Customs Service, as well as six members representing each geopolitical zone.⁶ All members, except the Executive Chairman and Executive Directors, serve on a part-time basis.⁷

2.2. The Joint Revenue Board of Nigeria (Establishment) Act (JRBA), 2025

The JRBA focuses on creating a harmonized framework for revenue administration and dispute settlement across all tiers of government in Nigeria.⁸ It achieves this by establishing three critical independent bodies:

The Joint Revenue Board (JRB): The JRB is established as a corporate body to ensure uniformity and resolve inter-agency disputes.S⁹ Its functions include integrating and maintaining a national database of Taxpayer Identification Numbers, resolving disputes between tax authorities on issues like residency, and advising the government on double taxation matters and the introduction of new taxes. The Board is composed of the Executive Chairman of the NRS, the Chairmen of all State and FCT Internal Revenue Services, and representatives from various federal agencies. Effective from the commencement date of the JRBA, the JRB replaces the existing Joint Tax Board.
The Tax Appeal Tribunal (TAT): The Act establishes the TAT to adjudicate tax disputes and controversies arising from any tax law made by the National Assembly or a State House of Assembly.¹⁰ Each zonal Tribunal consists of five Tax Appeal Commissioners appointed by the Minister of Finance. The Chairman of each zone must be a legal practitioner with at least 10 years of experience in tax matters. Appeals from the TAT on points of law can be made to the Federal High Court. This maintains the existing structure.
The Office of the Tax Ombud: This office is created as an independent and impartial arbiter to review and resolve taxpayer complaints against tax authorities.¹¹ Presently, there isn’t an existing ombudsman in Nigeria’s tax system. Its functions include investigating complaints, mediating disputes, making recommendations to revenue authorities, and raising awareness about taxpayer rights. The Office of the Tax Ombud cannot, however, interpret tax legislation or determine a tax liability.

2.3. The Nigeria Tax Administration Act (NTAA), 2025

The NTAA is the procedural and administrative pillar of the new tax regime established in the Nigeria Tax Act (NTA), providing a uniform set of rules for the administration, assessment, collection, and enforcement of taxes across the country. Its main objective is to create uniform procedures for a consistent and efficient administration of tax laws in order to facilitate taxpayer compliance and optimize revenue collection.¹² It applies to any person required to comply with any tax law in Nigeria. Its key provisions cover the areas highlighted below:

The Jurisdiction of Tax Authorities: It clearly defines the administrative powers of the NRS and the State Internal Revenue Services.¹³ The NRS has exclusive responsibility for taxes on companies, certain federal employees (Army, Navy, Air Force, Police, Foreign Service), and non-resident persons. State tax authorities are responsible for administering taxes for resident individuals.
Registration and Tax ID: Every taxable person, including government ministries and non-resident persons deriving income from Nigeria, is required to register with the relevant tax authority and obtain a Taxpayer Identification (Tax ID) number.¹⁴
Returns and Assessments: The NTAA provides detailed guidelines for filing various tax returns, including income tax returns for companies and individuals, Pay-As-You-Earn (PAYE) returns for employers, and VAT returns.¹⁵
It establishes self-assessment as the primary mode of assessment but empowers tax authorities to make administrative or additional assessments where returns are not filed or are inaccurate.¹⁶
Enforcement Powers: Tax authorities are now granted robust powers to enforce compliance including the power of substitution (appointing a third party, like a bank, to pay a taxpayer’s liability from funds it holds for the taxpayer) and the power to distrain (seizing and selling a taxpayer’s assets to recover tax debts).¹⁷
Offences and Penalties: The NTAA contains a comprehensive schedule of offences such as failure to register for tax, failure to file returns, and failure to remit deducted taxes, as well as administrative penalties for non-compliance.¹⁸

2.4. The Nigeria Tax Act (NTA), 2025

The NTA is the substantive law that imposes taxes. It consolidates and repeals a host of previous tax legislation including the Companies Income Tax Act, Personal Income Tax Act, Petroleum Profits Tax Act, Value Added Tax Act, and Stamp Duties Act, into a single, unified statute. Its primary objective is to provide a unified fiscal legislation governing the taxation of income, transactions, and instruments in Nigeria.¹⁹ Its key taxes and provisions include the following:

Income Tax: Tax is imposed on the profits of companies and the income of individuals.²⁰
The NTA sets the corporate income tax rate at 30% for medium and large companies and 0% for small companies.²¹
It also introduces a minimum effective tax rate of 15% for companies with a turnover of ₦20 billion and above and for constituent entities of Multinational Enterprise (MNE) groups.²²
For individuals, a progressive tax rate applies to chargeable income.
Tax on Petroleum Operations: The Act introduces a Hydrocarbon Tax (HCT) for companies in upstream petroleum operations under the Petroleum Industry Act.²³
It also retains the Petroleum Profits Tax (PPT) for certain existing oil prospecting licenses and oil mining leases that have not yet been converted under the new regime.²⁴
Value Added Tax (VAT): VAT is imposed at a rate of 7.5% on all taxable supplies of goods and services in Nigeria. The NTA provides a detailed list of exempt supplies (e.g., baby products, educational services) and zero-rated supplies (e.g., basic food items, medical products, exported goods).
Stamp Duties: Duties are imposed on a wide range of legal and commercial instruments at specified rates.
Surcharge and Levies: A 5% surcharge is imposed on chargeable fossil fuel products. Additionally, a 4% development levy is imposed on the assessable profits of companies (other than small and non-resident companies) to fund key national institutions like the Tertiary Education Trust Fund and Defence and Security Infrastructure Fund.
Tax Incentives: The NTA also consolidates and streamlines tax incentives, creating a framework for Economic Development Tax Incentives for companies operating in designated priority sectors. It also provides for specific income tax exemptions and deductible donations.

3. Conclusion

By repealing numerous legacy statutes and establishing a new, cohesive framework, these laws collectively aim to create a more efficient, harmonized, and transparent tax system. At the heart of this reform is a clear division of roles:

The Nigeria Revenue Service (Establishment) Act creates the new primary federal tax authority, the NRS, responsible for the assessment and collection of federal revenues.
The Nigeria Tax Administration Act provides the uniform procedural rules for the management of all taxes from registration and filing returns to assessments and enforcement.
The Nigeria Tax Act consolidates all substantive tax obligations into a single statute, imposing taxes on income, transactions, and instruments while streamlining incentives.
The Joint Revenue Board of Nigeria (Establishment) Act introduces crucial institutions for inter-governmental coordination and taxpayer protection, establishing the Joint Revenue Board, the Tax Appeal Tribunal, and the Office of the Tax Ombud.

Together, these laws mark a deliberate shift from a fragmented system to a unified one, designed to simplify compliance for taxpayers, optimize revenue for the government, and provide clear mechanisms for dispute resolution. The ultimate success of this ambitious reform will depend on the effective and consistent implementation by the newly established and restructured agencies.

With proper implementation, the Quadruplet Tax Laws hold the promise of building a more robust and sustainable fiscal foundation, which is essential for Nigeria’s long-term economic development. In my forthcoming article, ‘Crypto Tax: How Virtual Assets and Its Related Transactions Are Taxed in Nigeria,’ I will show the path to legal compliance for VASPs who are now expressly under the tax authority’s radar.