By AdaTax Matters | September 19, 2026
Nigeria’s tax reform journey has entered a new phase.
Barely nine months after the country’s new tax laws took effect, the Federal Government has commenced a six-week technical review aimed at identifying implementation gaps, resolving ambiguities and addressing unintended consequences emerging from the new tax framework.
The exercise, led by Taiwo Oyedele, Minister of Finance and Coordinating Minister of the Economy, will place several important areas of taxation under fresh review, including Value Added Tax (VAT), Withholding Tax (WHT), capital gains, multiple taxation and taxpayer compliance.
The recommendations are expected to contribute to the proposed Finance Bill 2027, while separate work will also be undertaken on revised withholding tax regulations and Nigeria’s Significant Economic Presence framework.
A New Phase for Nigeria’s Tax Reform
The review follows the implementation of four major tax laws from 1 January 2026:
- Nigeria Tax Act 2025;
- Nigeria Tax Administration Act 2025;
- Nigeria Revenue Service (Establishment) Act 2025; and
- Joint Revenue Board (Establishment) Act 2025.
According to Oyedele, the review is not intended to fundamentally rewrite the reforms enacted in 2025. Rather, it is designed to examine how the new framework has performed in practice and identify areas where clarification, simplification or further refinement may be required.
The Finance Bill 2027, he said, should therefore build on the existing reforms while responding to implementation challenges and emerging economic realities.
VAT, WHT and Capital Gains Take Centre Stage
One of the key areas attracting attention is Value Added Tax.
Stakeholder submissions have raised issues around VAT thresholds and the need for greater clarity and simplicity in implementation. The review will consider these concerns alongside other tax provisions that businesses have found challenging.
Withholding Tax is another major area on the review agenda.
The Technical Subcommittee will review the Deduction of Tax at Source Regulations 2024 and prepare revised withholding tax regulations to align with the new tax laws.
Oyedele reiterated that WHT is intended to operate as an advance-payment and compliance mechanism, rather than an additional tax cost or a mechanism that unnecessarily locks up businesses’ working capital.
The treatment of capital gains will also be reviewed, alongside concerns surrounding multiple taxation and the coordination of revenue authorities.
Government Receives 134 Stakeholder Submissions
The review comes after the Federal Government invited Nigerians and stakeholders to submit recommendations on the implementation of the tax reforms.
According to Oyedele, 134 submissions were received from across Nigeria’s six geopolitical zones, in addition to submissions received in hard copy.
The issues raised included:
- Simplification and clarification of tax laws;
- VAT thresholds;
- Withholding Tax;
- Capital gains treatment;
- Multiple taxation;
- Taxpayer rights;
- Faster tax refunds;
- Digitalisation and data sharing;
- Protection of small businesses; and
- Investment and business competitiveness.
The breadth of the submissions highlights the practical questions that have emerged as businesses, taxpayers and tax administrators adjust to the new tax architecture.
Multiple Taxation and Digital Compliance Under Review
Multiple taxation is another issue expected to receive attention.
Stakeholders have called for improved coordination among revenue authorities to reduce overlapping demands and unnecessary compliance burdens.
The review will also examine digitalisation and data sharing, including ways to reduce situations where taxpayers are repeatedly required to provide information that may already be available to government agencies.
For businesses, this area could have significant implications for the cost and efficiency of tax compliance.
Significant Economic Presence Framework Also on the Table
The review will extend beyond domestic tax administration.
The Companies Income Tax (Significant Economic Presence) Order 2020 will be examined, with the objective of developing an updated framework that aligns with the new tax laws and international practices.
This is particularly relevant to cross-border businesses and Nigeria’s approach to taxing economic activities carried out by non-resident companies.
The government has indicated that the framework should protect Nigeria’s taxing rights while also considering the country’s competitiveness for technology and international investment.
What Taxpayers Need to Know
For taxpayers and businesses, the most important point is that the review does not automatically change the tax laws currently in force.
The six-week exercise is a review process. Any eventual legislative or regulatory changes will still need to follow the applicable legal process.
In the meantime, taxpayers should:
1. Continue complying with existing tax obligations.
Businesses should not suspend current filing, payment or withholding obligations because a provision is under review.
2. Watch developments around WHT.
The proposed review of the Deduction of Tax at Source Regulations 2024 could affect how withholding obligations are administered in the future.
3. Monitor VAT developments.
Businesses should pay attention to any clarification or proposed changes concerning VAT thresholds and implementation.
4. Keep proper documentation.
Strong records remain essential while the tax administration framework continues to evolve.
5. Review exposure to multiple taxation.
Businesses dealing with different revenue authorities should monitor overlapping tax demands and maintain clear documentation supporting their compliance position.
6. Stay informed about Finance Bill 2027.
Recommendations from the review are expected to feed into the 2027 Finance Bill, making the legislative process an important development for taxpayers to follow.
What Comes Next?
The Technical Subcommittee has been given six weeks to complete its assignment and submit its report.
Its work will cover the preparation of the Finance Bill 2027, revision of withholding tax regulations and review of the Significant Economic Presence framework, alongside broader fiscal-policy issues.
For taxpayers, the coming weeks will therefore be important not because the existing tax regime has been suspended, but because the government is now examining how the reforms are working in practice and where adjustments may be required.
The AdaTax Matters Take
Nigeria’s tax reform story is moving from legislative reform to implementation and refinement.
The real significance of the six-week review will ultimately depend on the recommendations produced, the evidence considered and the changes that eventually make their way into legislation and regulations.
For businesses and tax professionals, the message at this stage is simple: stay compliant, stay informed and watch the review closely.
As Nigeria prepares for the 2027 fiscal year, developments from this six-week exercise could shape the next chapter of the country’s tax administration and compliance landscape.
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