1. Introduction
The enactment of the Nigeria Tax Administration Act (NTAA), 2025 represents a decisive step in Nigeria’s ongoing tax reform programme. While the Nigeria Tax Act, 2025 consolidates substantive tax laws, the NTAA 2025 serves as the procedural and administrative framework governing how taxes are assessed, collected, enforced, and accounted for across the Federation.
This article provides a professional analysis of the NTAA 2025, focusing on its objectives, scope of application, allocation of taxing authority, inter-governmental coordination, and accountability mechanisms. It explains how the Act seeks to resolve long-standing administrative inefficiencies while preserving constitutional tax powers.
2. Objective of the Nigeria Tax Administration Act, 2025
Section 1 of the NTAA 2025 clearly sets out its purpose:
To provide uniform procedures for a consistent and efficient administration of tax laws in order to:
Facilitate tax compliance by taxpayers, and
Optimise tax revenue for government.
This objective underscores a policy shift away from fragmented and discretionary enforcement practices towards a standardised, rules-based tax administration system. The Act recognises that sustainable revenue mobilisation is best achieved through clarity, predictability, and administrative efficiency rather than coercive enforcement.
3. Scope of Application
The NTAA 2025 applies to any person required to comply with any provision of the tax laws, whether acting:
Personally, or
On behalf of another person.
This includes individuals, companies, partnerships, trustees, executors, employers, agents, and other intermediaries involved in tax deduction, collection, remittance, or reporting.
The breadth of this provision is deliberate. It ensures that tax compliance obligations extend beyond primary taxpayers to all persons who play a role in the tax administration chain, thereby closing enforcement gaps and strengthening accountability.
4. Central Role of the Nigeria Revenue Service under the NTAA 2025
A cornerstone of the NTAA 2025 is the clear institutional positioning of the Nigeria Revenue Service (“the Service”) as the principal federal tax administrator, established under the Nigeria Revenue Service (Establishment) Act, 2025.
4.1 Exclusive Federal Administrative Responsibility
Under Section 3(1) of the NTAA 2025, the Service has exclusive responsibility for administering taxes relating to:
Companies
Members of the Armed Forces and the Nigeria Police Force (other than in a civilian capacity)
Officers of the Nigerian Foreign Service
Non-resident persons deriving income or profits from Nigeria
Specified federal taxes, including:
Development levy
Taxes payable by non-resident persons
Taxes on specialized trades or businesses
Taxes on income from petroleum operations
Surcharge on fossil fuels
Value Added Tax (VAT)
Economic development tax incentives
VAT exemptions
This exclusivity removes historical ambiguities surrounding jurisdiction, particularly in relation to non-residents, corporate taxpayers, and sector-specific taxes.
5. Concurrent Administrative Powers of the Service
In addition to its exclusive mandate, the Service is empowered to administer:
Income tax
Stamp duties
Tax incentives
These powers operate within a coordinated federal–state framework, ensuring consistency while respecting constitutional allocations of taxing authority.
6. Role of State and FCT Tax Authorities under the NTAA 2025
Section 3(2) of the NTAA 2025 preserves the authority of State and Federal Capital Territory tax authorities in respect of resident individuals, in accordance with the First Schedule to the Act.
Their responsibilities include:
Imposition of tax on income, profits, or gains
Ascertainment of:
Profits and income
Assessable income
Total income
Chargeable gains
Application of tax rates
These powers are expressly subject to federal exclusions, notably for:
Armed forces and police personnel
Officers of the Nigerian Foreign Service
Non-resident individuals
The Act therefore balances administrative harmonization with constitutional fiscal federalism.
7. Inter-Authority Delegation and Cooperation
Section 3(3) introduces a statutory mechanism for administrative delegation. A tax authority may, with the approval of the relevant government, authorize another tax authority to administer taxes within its jurisdiction on agreed terms.
This provision promotes:
Inter-agency collaboration
Efficient resource utilization
Reduced duplication of enforcement efforts
Improved taxpayer experience
It also provides a lawful basis for joint audits, shared infrastructure, and coordinated compliance initiatives.
8. Powers of Assessment, Collection, and Accountability
Under Section 3(4), tax authorities are empowered to take all actions deemed necessary and expedient for the assessment and collection of taxes. This confers wide operational discretion to ensure effective enforcement.
However, the Act imposes a corresponding accountability obligation. All taxes collected must be fully accounted for in accordance with:
The NTAA 2025
The Nigeria Tax Act, 2025
Other applicable federal or state legislation
This ensures transparency, fiscal discipline, and auditability in tax administration.
9. Legal and Practical Significance of the NTAA 2025
Taken together, the provisions of the Nigeria Tax Administration Act, 2025:
Establish a unified procedural framework for tax administration
Clearly delineate federal and state administrative responsibilities
Reduce jurisdictional conflicts and multiple taxation risks
Strengthen taxpayer certainty and compliance
Enhance revenue mobilization without undermining constitutional powers
The Act represents a move from fragmented administration to institutional coherence and procedural certainty.
10. Conclusion
The Nigeria Tax Administration Act, 2025 is the operational engine of Nigeria’s reformed tax system. By harmonizing procedures, clarifying institutional roles, enabling inter-agency cooperation, and embedding accountability, the Act lays the foundation for a modern, efficient, and credible tax administration framework.
Its success will ultimately depend on disciplined implementation, continuous capacity building, and sustained cooperation among tax authorities at all levels of government.