Nigeria Tax Act 2025

An Act To Repeal The Capital Gains Tax Act, The Casino Act, The Companies Income Tax Act, The Deep Offshore And Inland Basin Production Sharing Contracts Act, The Industrial Development (Income Tax Relief) Act, Income Tax (Authorised Communications) Act, Personal Income Tax Act, Stamp Duties Act, Value Added Tax Act And The Venture Capital (Incentives) Act To Amend The Nigeria Export Processing Zones Act, The Oil And Gas Free Trade Zone Act, The National Information Technology Development Agency Act, Petroleum Industry Act, Tertiary Education Trust Fund (Establishment, Etc.) Act, The National Agency For Science And Engineering Infrastructure Act, The Customs, Excise Tariffs, Etc. (Consolidation) Act, The National Lottery
Act, The Nigerian Minerals And Mining Act, The Nigeria Start-up Act, The Export (Incentives And Miscellaneous Provisions) Act, The Cybercrime
(Prohibition, Prevention, Etc.) Act, To Revoke The Value Added Tax Act (Modification) Order 2021, To Amend The Companies Income Tax
(Significant Economic Presence) Order, 2020 And The Petroleum (Drilling And Production) Regulations 1969, To Consolidate The Legal Frameworks Relating To Taxation And Enact The Nigeria Tax Act To Provide For Taxation Of Income, Transactions And Instruments; And For Related Matters.

Commencement [1st January, 2026]

ENACTED by the National Assembly of the Federal Republic of Nigeria –

Section

Section 1 Nigeria Tax Act 2025 – Objective

Section 2 Nigeria Tax Act 2025 – Application

CHAPTER TWO – TAXATION OF INCOME OF PERSON

Section 3 Nigeria Tax Act 2025 – Imposition of tax

Section 4 Nigeria Tax Act 2025 – Income, profits or gains chargeable to tax

Section 5 Nigeria Tax Act 2025 – Chargeability to tax

Part II – Taxation of Resident Persons

Section 6 Nigeria Tax Act 2025 – Nigerian company

Section 7 Nigeria Tax Act 2025 – Nigerian dividends

Section 8 Nigeria Tax Act 2025 – Profits of a company from certain dividends

Section 9 Nigeria Tax Act 2025 – Substitution of dividend for total profit

Section 10 Nigeria Tax Act 2025 – Certain undistributed profits may be treated as distributed

Section 11 Nigeria Tax Act 2025 – Partnership of companies

Section 12 Nigeria Tax Act 2025 – Resident individual

Section 13 Nigeria Tax Act 2025 – Employment income

Section 14 Nigeria Tax Act 2025 – Benefits-in-kind

Section 15 Nigeria Tax Act 2025 – Partnership of individuals

Section 16 Nigeria Tax Act 2025 – Settlements, trusts and estates

Section 17 Nigeria Tax Act 2025 – Non-resident person

Section 18 Nigeria Tax Act 2025 – Non-resident person engaged in shipping or air transport

Section 19 Nigeria Tax Act 2025 – Nigerian dividends received by non-resident persons

Part IV – Ascertainment of Profits and Income

Section 20 Nigeria Tax Act 2025 – Deductions allowed

Section 21 Nigeria Tax Act 2025 – Deductions not allowed

Part V – Ascertainment of Assessable Profits and Income

Section 22 Nigeria Tax Act 2025 – Basis for computing assessable profits for trade or business

Section 23 Nigeria Tax Act 2025 – Change in accounting date

Section 24 Nigeria Tax Act 2025 – Cessation of trade or business

Section 25 Nigeria Tax Act 2025 – Continuity of trades

Section 26 Nigeria Tax Act 2025 – Basis for computing assessable income

Part VI – Ascertainment of Total Profits of Companies

Section 27 Nigeria Tax Act 2025 – Ascertainment of total profits of companies

Part VII – Ascertainment of Total Income of an Individual

Section 28 Nigeria Tax Act 2025 – Total income of an individual

Section 29 Nigeria Tax Act 2025 – Presumptive taxation

Section 30 Nigeria Tax Act 2025 – Ascertainment of chargeable income of individuals

Section 31 Nigeria Tax Act 2025 – Deductions to be claimed

Section 32 Nigeria Tax Act 2025 – Proof of claims

Part VIII – Ascertainment of Chargeable Gains

Section 33 Nigeria Tax Act 2025 – Chargeable gains

Section 34 Nigeria Tax Act 2025 – Chargeable assets

Section 35 Nigeria Tax Act 2025 – Disposal of assets

Section 36 Nigeria Tax Act 2025 – Disposal of assets, provisions as to considerations

Section 37 Nigeria Tax Act 2025 – Compulsory acquisition of land

Section 38 Nigeria Tax Act 2025 – Date of acquisition or disposal

Section 39 Nigeria Tax Act 2025 – Computation of chargeable gains

Section 40 Nigeria Tax Act 2025 – Expenses incurred for disposal of chargeable assets

Section 41 Nigeria Tax Act 2025 – Part disposal

Section 42 Nigeria Tax Act 2025 – Consideration due after time of disposal

Section 43 Nigeria Tax Act 2025 – Assets lost or destroyed

Section 44 Nigeria Tax Act 2025 – Bargains comprising two or more transactions

Section 45 Nigeria Tax Act 2025 – Valuation at market value

Section 46 Nigeria Tax Act 2025 – Location of assets

Section 47 Nigeria Tax Act 2025 – Indirect transfer of ownership of companies or assets

Section 48 Nigeria Tax Act 2025 – Life assurance policies

Section 49 Nigeria Tax Act 2025 – Rights under policies of insurance, other than life assurance policies

Section 50 Nigeria Tax Act 2025 – Personal injury

Section 51 Nigeria Tax Act 2025 – Principal private residences

Section 52 Nigeria Tax Act 2025 – Personal chattels

Section 53 Nigeria Tax Act 2025 – Motor vehicles

Section 54 Nigeria Tax Act 2025 – Gifts

Section 55 Nigeria Tax Act 2025 – Assets held in trust for charities

Section 56 Nigeria Tax Act 2025 – Rate of tax for companies

Section 57 Nigeria Tax Act 2025 – Effective tax rate

Section 58 Nigeria Tax Act 2025 – Rates of tax for individuals

Part X – Development Levy

Section 59 Nigeria Tax Act 2025 – Development levy

Part XI – Specialised Trade or Business

Section 60 Nigeria Tax Act 2025 – Export processing and free trade zone entities

Section 61 Nigeria Tax Act 2025 – Insurance trade or business

Section 62 Nigeria Tax Act 2025 – Lottery and gaming trade or business

Section 63 Nigeria Tax Act 2025 – Collective investment scheme

Section 64 Nigeria Tax Act 2025 – Mining operations

CHAPTER THREE – TAXATION OF INCOME FROM PETROLEUM OPERATIONS

Part I – Hydrocarbon Tax, Ascertainment of Chargeable Tax, Ascertainment of Chargeable Profits and Consolidation for Tax Purposes

Section 65 Nigeria Tax Act 2025 – Application of this Part

Section 66 Nigeria Tax Act 2025 – Charge of hydrocarbon tax

Section 67 Nigeria Tax Act 2025 – Ascertainment of crude oil revenue, adjusted profit, assessable profits

Section 68 Nigeria Tax Act 2025 – Allowable deductions

Section 69 Nigeria Tax Act 2025 – Deductions not allowed

Section 70 Nigeria Tax Act 2025 – Assessable profits and losses

Section 71 Nigeria Tax Act 2025 – Chargeable profits and allowances

Section 72 Nigeria Tax Act 2025 – Chargeable hydrocarbon tax

Section 73 Nigeria Tax Act 2025 – Additional chargeable tax payable in certain circumstances

Section 74 Nigeria Tax Act 2025 – Pre-production cost

Section 75 Nigeria Tax Act 2025 – Trade or business sold or transferred

Section 76 Nigeria Tax Act 2025 – Consolidation of costs and revenue

Section 77 Nigeria Tax Act 2025 – Partnerships

Section 78 Nigeria Tax Act 2025 – Income tax on petroleum operations

Section 79 Nigeria Tax Act 2025 – Registration and use of separate company for each stream of petroleum operations

Section 80 Nigeria Tax Act 2025 – Provisions relating to gas

Section 81 Nigeria Tax Act 2025 – Allowances for the purposes of income tax on petroleum operations

Section 82 Nigeria Tax Act 2025 – Expense deductibility

Section 83 Nigeria Tax Act 2025 – Basis period for income tax on petroleum operations

Section 84 Nigeria Tax Act 2025 – Additional income tax payable in certain circumstances

Section 85 Nigeria Tax Act 2025 – Non-Associated gas greenfield developments in onshore and shallow water terrains

Section 86 Nigeria Tax Act 2025 – Provision relating to decommissioning and abandonment of funds

Section 87 Nigeria Tax Act 2025 – General application of this Part and other matters

Section 88 Nigeria Tax Act 2025 – Fiscal stabilisation

Section 89 Nigeria Tax Act 2025 – Petroleum royalty

Part II – Petroleum Profits Tax Imposition Of Tax And Ascertainment Of Chargeable Profits, Ascertainment Of Assessable Tax And Of Chargeable Tax

Section 90 Nigeria Tax Act 2025 – Charge of petroleum profits tax

Section 91 Nigeria Tax Act 2025 – Ascertainment of profits, adjusted profit, assessable profits and chargeable profits

Section 92 Nigeria Tax Act 2025 – Deductions allowed

Section 93 Nigeria Tax Act 2025 – Incentives for utilisation of associated gas

Section 94 Nigeria Tax Act 2025 – Application of incentives to utilisation of non-associated gas

Section 95 Nigeria Tax Act 2025 – Deductions not allowed

Section 96 Nigeria Tax Act 2025 – Exclusion of certain profits

Section 97 Nigeria Tax Act 2025 – Assessable profits and losses

Section 98 Nigeria Tax Act 2025 – Chargeable profits and capital allowances

Section 99 Nigeria Tax Act 2025 – Assessable petroleum profits tax

Section 100 Nigeria Tax Act 2025 – Additional chargeable tax payable in certain circumstances

Section 101 Nigeria Tax Act 2025 – Partnerships

Part III – Deep Offshore and Inland Basin Production Sharing Contracts

Section 102 Nigeria Tax Act 2025 – Production sharing contracts

Section 103 Nigeria Tax Act 2025 – Duration of oil prospecting licence

Section 104 Nigeria Tax Act 2025 – Determination of petroleum profits tax

Section 105 Nigeria Tax Act 2025 – Determination of investment tax allowance

Section 106 Nigeria Tax Act 2025 – Royalty payable in respect of deep offshore production sharing contracts

Section 107 Nigeria Tax Act 2025 – Computation of petroleum profit tax

Section 108 Nigeria Tax Act 2025 – Allocation of royalty oil

Section 109 Nigeria Tax Act 2025 – Allocation of cost oil

Section 110 Nigeria Tax Act 2025 – Allocation of tax oil

Section 111 Nigeria Tax Act 2025 – Allocation of profit oil

Section 112 Nigeria Tax Act 2025 – Payment royalty

Section 113 Nigeria Tax Act 2025 – Chargeable tax petroleum operations

Section 114 Nigeria Tax Act 2025 – Use of realisable price in determining royalty and petroleum profits tax in respect of crude oil

Section 115 Nigeria Tax Act 2025 – Submission of receipts

Section 116 Nigeria Tax Act 2025 – Adaptation of laws

Section 117 Nigeria Tax Act 2025 – Review of the production sharing contract

Part IV – Miscellaneous Provisions

Section 118 Nigeria Tax Act 2025 – Administration of royalties

Section 119 Nigeria Tax Act 2025 – Interpretation

CHAPTER FOUR – RELIEF FOR DOUBLE TAXATION

Section 120 Nigeria Tax Act 2025 – Unilateral relief of double taxation

Section 121 Nigeria Tax Act 2025 – Double taxation agreement

Section 122 Nigeria Tax Act 2025 – Method of calculating relief to be allowed for double taxation

Section 123 Nigeria Tax Act 2025 – Interpretation

CHAPTER FIVE – TAXATION OF DUTIABLE INSTRUMENTS

Part I – Imposition Of Stamp Duties

Section 124 Nigeria Tax Act 2025 – Charge of duties

Section 125 Nigeria Tax Act 2025 – Manner of denoting duty

Section 126 Nigeria Tax Act 2025 – Obligation to stamp

Section 127 Nigeria Tax Act 2025 – Admissible evidence

Part II – Chargeable Instruments

Section 128 Nigeria Tax Act 2025 – Bill of exchange

Section 129 Nigeria Tax Act 2025 – Promissory Note

Section 130 Nigeria Tax Act 2025 – Sale or purchase of options

Section 131 Nigeria Tax Act 2025 – Conveyance on sale

Section 132 Nigeria Tax Act 2025 – Conveyance in consideration of a debt

Section 133 Nigeria Tax Act 2025 – Duty on transfer of mineral assets

Section 134 Nigeria Tax Act 2025 – Provisions as to exchange

Section 135 Nigeria Tax Act 2025 – Leases

Section 136 Nigeria Tax Act 2025 – Duty on share capital

Section 137 Nigeria Tax Act 2025 – Duty on loan capital

Section 138 Nigeria Tax Act 2025 – Marketable security

Section 139 Nigeria Tax Act 2025 – Appraisements

Part III – Miscellaneous Provisions

Section 140 Nigeria Tax Act 2025 – Duplicates and counterparts

Section 141 Nigeria Tax Act 2025 – Duty relating to one instrument covering multiple transactions

Section 142 Nigeria Tax Act 2025 – Duty relating to multiple instruments covering same transaction

Section 143 Nigeria Tax Act 2025 – Provisions on non-monetary consideration

CHAPTER SIX – VALUE ADDED TAX
Part I – Imposition Of Value Added Tax

Section 144 Nigeria Tax Act 2025 – Imposition of value added tax

Section 145 Nigeria Tax Act 2025 – Charge of VAT

Section 146 Nigeria Tax Act 2025 – Taxable supplies

Section 147 Nigeria Tax Act 2025 – Time of supply

Section 148 Nigeria Tax Act 2025 – Rate of VAT

Section 149 Nigeria Tax Act 2025 – Value of taxable supplies

Section 150 Nigeria Tax Act 2025 – Value of imported taxable supply

Section 151 Nigeria Tax Act 2025 – Taxable supply of non-residents

Part II – Remittances and Recovery of VAT

Section 152 Nigeria Tax Act 2025 – Payment of VAT by taxable person

Section 153 Nigeria Tax Act 2025 – VAT Invoice

Section 154 Nigeria Tax Act 2025 – Collection of VAT by taxable person

Section 155 Nigeria Tax Act 2025 – Collection of VAT by persons other than the supplier

Section 156 Nigeria Tax Act 2025 – Credit for input tax and remission of VAT

Section 157 Nigeria Tax Act 2025 – Business sold out

Section 158 Nigeria Tax Act 2025 – Fiscalisation of supplies for VAT

Section 159 Nigeria Tax Act 2025 – Imposition of surcharge

Section 160 Nigeria Tax Act 2025 – Chargeable transaction and base for surcharge

Section 161 Nigeria Tax Act 2025 – Administration of the surcharge

Section 162 Nigeria Tax Act 2025 – Exemption from surcharge

CHAPTER EIGHT – TAX INCENTIVES
Part I – Income Tax Exemptions

Section 163 Nigeria Tax Act 2025 – Income tax exemption

Section 164 Nigeria Tax Act 2025 – Deductible donations

Section 165 Nigeria Tax Act 2025 – Deduction for research and development

Part II – Economic Development Tax Incentives

Section 166 Nigeria Tax Act 2025 – Priority sectors

Section 167 Nigeria Tax Act 2025 – Eligibility for economic development incentive certificate

Section 168 Nigeria Tax Act 2025 – Application for economic development incentive certificate

Section 169 Nigeria Tax Act 2025 – Approval of application

Section 170 Nigeria Tax Act 2025 – Terms of economic development incentive certificate

Section 171 Nigeria Tax Act 2025 – Addition of product to the economic development incentive certificate

Section 172 Nigeria Tax Act 2025 – Application of economic development incentive certificate

Section 173 Nigeria Tax Act 2025 – Production day and qualifying capital expenditure

Section 174 Nigeria Tax Act 2025 – Cancellation of economic development incentive certificate

Section 175 Nigeria Tax Act 2025 – Information

Section 176 Nigeria Tax Act 2025 – Publication of economic development incentive certificate

Section 177 Nigeria Tax Act 2025 – Economic development tax credit

Section 178 Nigeria Tax Act 2025 – Economic development incentive period

Section 179 Nigeria Tax Act 2025 – Books and records for priority products

Section 180 Nigeria Tax Act 2025 – Returns of profits

Section 181 Nigeria Tax Act 2025 – Cancellation or discountenance of economic development tax credit

Section 182 Nigeria Tax Act 2025 – Provisions for plantation industry

Section 183 Nigeria Tax Act 2025 – Exclusion from other reliefs and transition arrangements

Section 184 Nigeria Tax Act 2025 – Interpretation

Part III – Exemption From Stamp Duties

Section 185 Nigeria Tax Act 2025 – Exemption from stamp duties

Part IV – Exemption From VAT

Section 186 Nigeria Tax Act 2025 – Exempt supplies

Section 187 Nigeria Tax Act 2025 – Taxable supplies chargeable at 0%

Section 188 Nigeria Tax Act 2025 – Exemption by order of the President

Section 189 Nigeria Tax Act 2025 – Interpretation

CHAPTER NINE – GENERAL PROVISIONS

Section 190 Nigeria Tax Act 2025 – Business restructuring

Section 191 Nigeria Tax Act 2025 – Artificial transactions

Section 192 Nigeria Tax Act 2025 – Transactions between related parties to be at arm’s length

Section 193 Nigeria Tax Act 2025 – Waivers or refund of liability or expenses

Section 194 Nigeria Tax Act 2025 – Supplemental

Section 195 Nigeria Tax Act 2025 – Power to make regulation

Section 196 Nigeria Tax Act 2025 – Repeals

Section 197 Nigeria Tax Act 2025 – Consequential amendments

Section 198 Nigeria Tax Act 2025 – Revocation and consequential amendment of subsidiary legislation

Section 199 Nigeria Tax Act 2025 – Savings provisions

Section 200 Nigeria Tax Act 2025 – Exercise of powers, duties and obligations

Section 201 Nigeria Tax Act 2025 – Conflict with other laws

Section 202 Nigeria Tax Act 2025 – General interpretation

Section 203 Nigeria Tax Act 2025 – Citation

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