Businesses facing prolonged tax disputes and uncertainty over refunds want the government’s review of the new tax laws to provide clearer rules, faster resolution of disputes, and greater certainty around their tax obligations ahead of the 2027 Finance Bill.
‘After filing our tax returns, we received an assessment that we disagreed with. We submitted an objection, but the delay in resolving it left us uncertain about our outstanding tax obligations and made financial planning difficult,’ said an SME in Lagos that faced such issue.
This experience, amongst others, reflects some of the recurring concerns tax professionals say businesses encounter under Nigeria’s current tax framework, particularly when assessments are disputed or tax positions remain unresolved for extended periods.
Yvone Afolabi, a tax expert, highlighted that disputed assessments, delays in resolving objections, uncertainty around tax credits and refunds, and the administrative burden of complying with multiple tax requirements remain key concerns for taxpayers.
‘Businesses can also face cash-flow pressure when tax positions remain unresolved for extended periods’, she said.
The federal government has, however, commenced a six week review of the implementation of the new tax laws as it begins work on the 2027 Finance Bill, following concerns emerging from their implementation since January 2026.
Taiwo Oyedele, Minister of Finance and coordinating minister of the economy, announced that the government received 134 submissions from stakeholders across Nigeria’s geopolitical zones following a public call for input.
The submissions are expected to help identify areas requiring clarification, refinement or further reform.
Oyedele said the review was not intended to rewrite the 2025 reforms but to preserve their fundamental principles while responding to lessons from implementation and changing economic realities.
Tax professionals who spoke with BusinessDay said the review provides an opportunity to address areas where the new framework remains unclear or creates uncertainty for businesses.
Opeoluwa Ogundipe, a tax professional, said greater clarity was needed around what constitutes a Nigerian company and the meaning of effective place of management or control, particularly for multinational enterprises.
‘I hope the guidelines to be released will touch on what constitutes an effective phase of management or control, because the provision is a bit unclear, especial for MNEs’, he said, in relation to what the law says in section 147 of Nigeria Tax Administrative Act (NTAA)
Afolabi also urged that if she had the opportunity to recommend one specific amendment to the government ahead of the review, she will recommend ‘greater certainty around tax refunds, credits and disputed assessments, with clear statutory timelines and consequences for prolonged administrative delays’
According to her, clearer timelines would give businesses greater confidence in their tax positions, improve cash-flow planning and particularly help Small and Medium-sized Enterprises (SMEs) and businesses with significant VAT credits or genuine tax overpayments.
Abiodun Kayode-Alli, associate tax director PwC also pointed out that there’s still no official date for when the capital gains tax will take effect, and there should be more clarity for companies in the free trade zone on the criterias required for them to enjoy the tax exemptions provided
George Mbuba, a legal practitioner, has also proposed targeted amendments to the Nigeria Tax Act to address what he sees as gaps that could create uncertainty or unfair outcomes.
One of his proposals is an inflation adjustment for chargeable gains under Section 39 of the Nigeria Tax Act. His argument is that taxing gains using the original naira cost of an asset can overstate the actual economic gain where the asset has been held for several years and prices have risen substantially.
Mbuba’s proposal would allow the deductible cost of an asset to be adjusted using the change in the National Bureau of Statistics’ All-Items Consumer Price Index between the date of acquisition and disposal, subject to a safeguard preventing the adjustment from turning a genuine gain into a tax loss.
He also proposed a statutory test for determining when an individual is resident in Nigeria under Section 201 of the Nigeria Tax Act. His proposal would introduce a clearer 183-day sojourn test, supported by other factors such as domicile, habitual abode and substantial economic or personal ties, with an exception for diplomats.
The proposals come as the government reviews the implementation of the four major tax laws that took effect on January 1, 2026, with stakeholders also calling for clearer VAT thresholds, simpler withholding-tax provisions, stronger taxpayer protections, faster refunds and better coordination among revenue authorities.