The review is a direct response to operational frictions identified since the primary tax reform package came into full effect on January 1, 2026. This package, enacted in 2025, comprises the Nigeria Tax Act, the Nigeria Tax Administration Act, the Nigeria Revenue Service Establishment Act, and the Joint Revenue Board Establishment Act. Oyedele clarified that the initiative is not intended to overturn the structural legislation established in 2025, but rather to preserve its foundational principles while adapting to lessons learned during administrative execution. He described the process as a transition from macro-level tax architecture restructuring toward operational refinement.
The subcommittee’s mandate is informed by a nationwide Call for Inputs, which yielded 134 formal submissions across all six geopolitical zones. Stakeholders from the public and private sectors raised concerns regarding specific operational friction points, including the lack of clarity surrounding Value Added Tax (VAT) thresholds, withholding tax deductions, and capital gains tax assessments. A persistent issue highlighted in the submissions was multiple taxation imposed by overlapping sub-national revenue jurisdictions.
Stakeholders also emphasized the necessity for accelerated taxpayer refunds, stronger administrative protections for small and medium enterprises, and integrated digital platforms to eliminate duplicate data submissions across government agencies. Additional proposals sought measures to bolster investment and competitiveness in critical sectors such as mining, renewable energy, healthcare, and capital markets.
To address these concerns, the minister directed the subcommittee to execute targeted technical reviews across two main regulatory instruments. First, the committee will evaluate the Deduction of Tax at Source Regulations 2024 against primary tax legislation to formulate updated Withholding Tax Regulations. Oyedele noted that withholding tax must function strictly as an advance compliance mechanism rather than an additional tax on working capital or an added expense for operating businesses.
Second, the committee is tasked with reviewing the Companies Income Tax Significant Economic Presence Order 2020. This mandate aims to establish an updated legal framework that safeguards Nigeria’s sovereign taxing rights over multinational digital commerce while maintaining market competitiveness for cross-border technology investments. The scope of the review extends beyond taxation to broader aspects of fiscal policy, including public financial management, national debt, transparency, and cross-border capital flows.
The technical subcommittee convenes representatives from the Ministry of Finance, Ministry of Justice, Nigeria Revenue Service, Joint Revenue Board, Nigeria Customs Service, the Small and Medium Enterprises Development Agency of Nigeria (SMEDAN), organized private sector associations, and professional accounting bodies. Oyedele instructed members to maintain confidentiality over their deliberations and working drafts until authorized for release, while requiring disclosures and recusals for any conflicts of interest.
“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,” Oyedele stated, emphasizing that implementation inevitably reveals areas requiring clarification and refinement. He added that the Finance Bill 2027 should not be viewed merely as an annual legislative exercise, but as a tool to enhance commercial predictability and lower compliance barriers for domestic and international investors.
The subcommittee is required to assess proposed changes based on the problems they seek to solve, their costs, beneficiaries, and possible unintended consequences. Oyedele urged the committee to consider the economic impact of any proposed changes, particularly on vulnerable segments of the population, including low-income households, workers, and businesses. The committee is expected to submit its report within the six-week deadline, with its findings forming a crucial part of the Finance Bill 2027.
