Nigeria's New Tax Regime (2025): Institutional Consolidation, Administrative Ambition, and the Limits of Legal Design

Abstract

Nigeria's 2025 tax reforms represent the most comprehensive restructuring of the country's fiscal framework since the return to constitutional government. Rather than pursuing incremental amendment, the legislature adopted a system-level approach, consolidating substantive tax liability, administrative procedure, and institutional authority into an integrated statutory architecture. This paper examines the reforms as an exercise in legal design, focusing on how consolidation and procedural uniformity redistribute power within Nigeria's federal system. The paper argues that while the new regime achieves a high degree of statutory coherence, it simultaneously concentrates administrative authority at the federal level in ways that strain fiscal federalism, distort enforcement incentives, and generate predictable litigation risk. The unification of income taxation, the replacement of multiple earmarked levies with a single Development Levy, and the imposition of a harmonised procedural code narrow opportunities for arbitrage but expand the significance of administrative discretion. Data-dependent enforcement mechanisms further intensify pressure on the formal sector while leaving structurally opaque economic activity beyond effective reach. Through doctrinal analysis of the Nigeria Tax Act, the Nigeria Tax Administration Act, and the establishment statutes for the Nigeria Revenue Service and the Joint Revenue Board, the paper identifies the limits of statutory coherence in the absence of institutional restraint. It concludes that the durability of the 2025 regime will be determined less by revenue yield than by how courts respond to disputes arising from procedural centralisation, enforcement asymmetry, and the concentration of fiscal power.

Nigeria’s New Tax Regime (2025) Institutional Consolidation, Administrative Ambition, and .

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