Nigeria’s historic tax reform: A game-changer with missing pieces

Port infrastructure revenue
This is potentially the largest economic sector outside oil and gas. A report by a Dutch consultancy firm, Dynanmar, shows that Nigeria loses about N20 billion daily (which annually is about N8 trillion) at the Lagos ports due to poor infrastructure. In other maritime sectors, Nigeria is estimated to be capable of generating N7 trillion annually and four million jobs over four years, but to deliver this, the following needs to be done: overhaul of ports infrastructure, Cabotage enforcement, the passage of critical maritime legislation like the Maritime Zones Bill, Ports Harbour Bill, etc. These laws, when passed, will generate non-tax revenue and attract massive investments in the sector.

Satellite technology revenue
Space is the next big investment arena. Space infrastructure companies received a record $14.5 billion of private investment in 2021, and the numbers are growing. These companies are ushering in next-generation small satellite capabilities with enormous value to commercial and government customers, including organisations in Energy, Mining, Manufacturing, Transportation, Finance, Security, Agriculture, and Communications.

For Nigeria to fully derive benefit from these opportunities in terms of investments and development, including revenue and jobs, the 2006 Space Policy and the 2010 National Space Research and Development Agency (NASRDA) Act need to be updated. The Government needs to issue an Executive Order mandating Ministries, Departments and Agencies (MDAs) to procure only satellite data generated by NASRDA.

Judgment debts
Nigeria’s Federal Government is owed approximately N5.2 trillion in judgment debts by over 5,000+ debtors across ten (10) Ministries, Departments and Agencies (MDAs). These debts are in the form of debt liabilities to the Federal Inland Revenue Service (FIRS); refunds to the Government by companies who failed to deliver on projects for which payment had been effected, unpaid credit facilities granted to both corporate entities and individuals by the Bank of Industry (BOI) and Bank of Agriculture (BOA); judgment debt in favour of Government, debts owed Pension Transitional Arrangement Directorate (PTAD) by Insurance Companies etc. To recover these debts, there needs to be an inventory of all debts owed to the federal government. The Federal Government also needs to put in place an appropriate policy and legal framework to facilitate the recovery of these debts.

Looking forward
While the tax reform bills represent a monumental step forward in modernising Nigeria’s revenue system, they address only half of the revenue equation. The government must now turn its attention to the vast untapped potential in non-tax revenue streams. This requires not just policy changes but fundamental shifts in how government assets are managed, how compliance is enforced across MDAs, and how revenue generation is conceptualised beyond traditional taxation.

Given the scale of Nigeria’s 2025 budget deficit of N13.08 trillion, the urgency of developing non-tax revenue sources cannot be overstated. The potential N100 trillion from non-tax sources could not only eliminate the budget deficit but also reduce Nigeria’s dangerous dependence on borrowing, which threatens to push public debt beyond sustainable levels.

The success of these tax reforms will ultimately be measured not just by increased tax compliance and collection, but by their contribution to Nigeria’s overall fiscal sustainability. To truly address the country’s revenue challenges and reduce its dangerous dependence on borrowing, Nigeria must embrace a comprehensive revenue strategy that harnesses both tax and non-tax opportunities.

As the effective date of the new Acts approaches (expected to be no earlier than January 1, 2026), businesses and government agencies alike must prepare for this new era in Nigerian fiscal policy. The transformation has begun, but the work of building a truly robust and diversified revenue base is far from complete.

Okeke and Okundaye are Associate Partners at Olisa Agbakoba Legal.

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