The first quarter of 2026 marked a decisive shift from reform to implementation in Nigeria’s tax landscape. Having enacted the most comprehensive overhaul of its tax framework in decades, the Federal Government entered the year with a focus on translating legislative intent to practical implementation. Courts and tribunals played a central role in defining the contours of this new framework, issuing landmark decisions that clarified statutory powers of certain institutional bodies, affirmed statutory tax obligations, and reinforced the primacy of due process in tax administration.
At the legislative level, the quarter saw growing subnational alignment with the federal tax reform, and the introduction of a statute aimed at eliminating nuisance taxes, among other notable developments. On the policy and administrative front, the quarter witnessed the issuance of public notices in line with key provisions of the Nigeria Tax Administration Act, the introduction of the guidelines for phased rollout of the e-invoicing system to medium and emerging taxpayers, as well as the issuance of comprehensive guidelines for personal income tax administration under the new tax regime, to mention a few.
This edition examines these developments in detail and underscores the urgency with which individual and corporate taxpayers must engage their obligations. As enforcement intensifies, proactive compliance remains imperative.
Judicial developments shaping Nigerian tax
The courts and tribunals delivered several decisions of practical consequence during the quarter.
In Amadeus Marketing Nigeria Limited v Economic and Financial Crimes Commission, the Federal High Court held that the EFCC has no power to assess or demand payment of tax liabilities. That decision matters for any business facing a demand from an agency other than the revenue authority.
The Federal High Court also affirmed, in Shell Exploration and Production Africa Limited v Federal Inland Revenue Service, that tertiary education tax is an annual tax. Consequently, it cannot be prorated within an accounting year.
Tribunal decisions on assessment and filing
The Tax Appeal Tribunal addressed filing obligations in Oando Deep Water Exploration Nigeria Limited v Federal Inland Revenue Service. It affirmed that petroleum companies operating under a production sharing contract must file petroleum profits tax returns, even at exploratory stage.
In Access Bank Plc v Anambra State Internal Revenue Service, the Tribunal turned to limitation. It affirmed the conditions precedent that a revenue authority must satisfy before raising additional assessments outside the limitation period.
Meanwhile, the Supreme Court upheld the fiscal incentives and guarantees granted to Nigeria LNG Limited under the NLNG Act, in its dispute with the Nigeria Maritime Administration and Safety Agency.
Why these decisions matter
Taken together, the decisions sharpen the boundaries of who may assess tax and on what basis. They also reinforce the procedural discipline expected of revenue authorities.
For taxpayers, the practical lesson is to test the authority behind any demand before responding to it.
Our newsletter examines each development, alongside the legislative and administrative changes of the quarter. Click the button below to read the publication.
