09/10/2025
The key changes in Nigeria’s new tax laws (the “Nigeria Tax Act / Tax Reform Acts, 2025”) and what you need to know.
These take effect January 1, 2026.
Major Highlights
1. Consolidation of Tax Laws
Several existing tax statutes (Companies Income Tax, Personal Income Tax, VAT Act, Capital Gains Tax, Petroleum Profits Tax, Stamp Duties, etc.) are being repealed and replaced with a unified, modern tax framework.
2. New Tax Authorities / Administration
The Nigeria Revenue Service (NRS) replaces the old Federal Inland Revenue Service (FIRS) as the main body for collecting federal taxes.
There is also stronger harmonization between federal and state tax administration; more central coordination and uniform rules.
An Office of the Tax Ombudsman is created to handle taxpayer complaints & disputes.
3. Personal Income Tax (PIT) & What It Means for Individuals
Exemption for low earners: Individuals earning ₦800,000 or less annually (after allowances etc.) are exempt from PIT.
Rent relief: There is a rent relief deduction (some limits apply).
Residency rules clarified: Clearer rules for who counts as a tax resident. Residency may be established by presence in Nigeria (183 days or more), family/economic ties, maintaining a permanent home, etc. Resident individuals now will be taxed on worldwide income, nonresidents only on Nigerian-source income.
Expanded taxable sources: Income from digital and virtual assets (crypto, NFTs etc.), prizes, grants, in-kind benefits etc. are expressly included.
4. Corporate Tax & Businesses
Small business exemption: Companies with gross turnover ≤ ₦100 million and fixed assets ≤ ₦250 million qualify for full exemption from Companies Income Tax, Capital Gains Tax, and the new Development Levy.
Development Levy: A new 4% levy on assessable profits of companies above the small business threshold, replacing several overlapping levies (tertiary education tax, IT levy, Police Trust Fund levy, etc.)
Minimum Effective Tax Rate (ETR): Large companies (turnover or group thresholds apply) must pay at least a 15% effective tax rate. If their tax liability is below that, they will need to top up.
5. Capital Gains Tax (CGT)
For companies: rate increased (aligned with CIT) from 10% to about 30%.
For individuals: CGT now taxed using the progressive income tax rates rather than a flat rate.
6. VAT & Consumption Taxes
VAT rate stays at 7.5% (for now) rather than being increased.
Certain essential goods and services are zero-rated or exempt: basic food, education, healthcare, public transport, etc.
Stronger rules for VAT input credits so businesses can offset VAT paid on goods and services — reducing cascading tax effects.
7. Penalties, Compliance & Enforcement
Hefty fines for non-filing, non-registration, or late registration. For example, failing to file can lead to a fine of ₦100,000 the first month, plus ₦50,000 per subsequent month.
Greater powers for tax authorities: increased digital surveillance, reporting obligations (e.g. banks reporting large transactions), stricter enforcement of tax compliance.
All taxable persons must have a Tax Identification Number (TIN / UTIN).
What This Means / Things to Watch Out For
Good news for many low-income earners & small businesses: The exemptions and reliefs mean many people and small enterprises will see reduced tax burden (or zero PIT / CIT).
But higher earners and multinationals will face new liabilities: broader tax base, new rules for digital income, higher CGT, minimum tax rules, etc.
Digital economy now taxed explicitly: If you earn through digital services, or virtual assets, you are more likely to be in scope.
More record-keeping and documentation required: Because of expanded taxable categories, stricter filing deadlines, reliefs requiring credible proof etc.
Monitoring of financial transactions: Banks must report large transactions; there will be more tracking of income flows.
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