Global audit firm KPMG says it has identified major loopholes and inconsistencies in Nigeria’s new tax laws, calling for urgent reviews to meet the objectives of the reforms. The firm disclosed this in a newsletter analysing the Nigeria Tax Act and the Nigeria Tax Administration Act, which became effective on January 1, 2026, following President Bola Tinubu’s assent in June last year.
KPMG said while the laws were designed to improve revenue oversight and streamline tax administration, several provisions contain errors, gaps and omissions. It cited concerns over the definition of taxable persons, treatment of controlled foreign company income, and differences in how dividends from Nigerian and foreign companies are taxed.
The firm also raised issues around the taxation of non-resident persons, noting that the laws do not clearly exempt non-residents without permanent establishment or significant economic presence from tax registration. It recommended amendments to provide clarity and align the provisions with the intended policy direction.
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KPMG further questioned restrictions on foreign exchange expense deductions and provisions denying tax deductions on expenses where value-added tax was not charged by suppliers. The firm said that although the laws have the potential to boost government revenue if well implemented, clarity and balance are needed to support sustainable economic growth.
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