Nigeria's two tax Act texts and the figures in dispute
Why two official texts of Nigeria's 2025 tax Acts exist, which figures differ, and how Achekam holds a disputed figure until two administrators settle it.
By Achekam · · 5 min read · For Running a business businesses in Nigeria
Most tax questions have one answer you can look up. Nigeria's 2025 reform has produced a stranger problem: for a handful of figures, there are two official answers, and they disagree. A business owner who asks "what is the limit?" can be given different numbers by two advisers who are both reading the law correctly.
That is not a reason to panic, but it is a reason to know where the disagreement sits, which figures it touches, and how to make a decision you can defend later. This article explains the two texts, gives one worked example, and describes how Achekam deals with a figure that the law has not settled.
The gazetted text and the January 2026 copy
The Nigeria Tax Act 2025 and its companion Acts came into force on 1 January 2026. They replaced a long list of older laws, and tax periods that ended before that date stay under the repealed rules. Over the same change, the Federal Inland Revenue Service became the Nigeria Revenue Service, the NRS.
Two official versions of the 2025 Acts now exist. The first is the version published in the Federal Government's gazette by FIRS. The second is the copy the National Assembly released in January 2026 as a true copy of the Acts it passed. On most provisions the two say the same thing. On some figures they do not.
If you want to read the gazetted wording for yourself, Lagos State's revenue service hosts the full gazetted text of the Nigeria Tax Act 2025, the law on income tax, the minimum effective tax rate, the development levy, VAT and stamp duties from 1 January 2026.
Which text the NRS says it applies
The NRS has said it applies the gazetted laws. Re-gazetting has been ordered, so the published text may still change, but until it does, the authority that assesses you is working from the gazette.
That gives a business a sensible default: plan on the gazetted figure, because that is what the NRS applies today, while keeping track of the other figure in case the re-gazetted text adopts it. What you should not do is pick whichever figure suits you best and forget that the other one exists.
The small-business limit as an example
The clearest example is the small-business VAT exemption. Under the new law, a small business in Nigeria does not have to register for VAT, charge it or file VAT returns, though it may opt in. The old ₦25 million VAT threshold is gone.
The difficulty is the turnover limit that defines "small". The gazetted text says ₦50 million. The National Assembly's January copy says ₦100 million.
Work through what that means in words. A trading company whose turnover sits comfortably under the lower figure is small on either reading: no disagreement. A company comfortably above the higher figure is outside the exemption on either reading. The company with turnover between the two figures is the one with a real question: it is outside the exemption on the gazetted text and inside it on the January copy. If that is you, the decision about charging VAT is a judgement, not a lookup, and it should be made with your adviser and written down. The exemption itself is covered in Nigeria's small-business VAT exemption.
Two administrators before a contested figure is used
Achekam does not guess between the two texts. Every Nigerian and Kenyan tax figure in its rule book was loaded "under review", and nothing is computed from a figure until an Achekam platform administrator approves it. No user in a business or an accounting firm can change a rate.
Three Nigerian figures get extra care because the sources disagree about them: the small-company turnover limit, the turnover threshold for the minimum effective tax rate, and the monthly PAYE remittance day. For each of these, one platform administrator must choose a candidate and record the reason, and a different administrator must approve that choice. Until both steps are done, Achekam does not use the figure at all.
Achekam also holds no Nigerian tax rule for periods before 1 January 2026, and refuses to compute those periods. Older years belong to the repealed laws and should be handled with your adviser.
UNDETERMINED until then, with what each candidate gives
While a contested figure is unsettled, Achekam shows the affected size class as UNDETERMINED, and alongside it shows what each candidate figure would give. For a company near the small-company limit, that means you see both outcomes side by side rather than a confident answer resting on one reading of the law.
This is more useful than it sounds. A company that lands in the same class on both candidates can stop worrying. A company that lands in different classes can see exactly what is at stake, such as whether company income tax, VAT or the development levy would apply, and take advice on that specific point.
Writing down the position you take
Whatever you decide, record it. A short note in your tax file is enough, and it protects you if the NRS, an auditor or a future accountant asks why you treated a year the way you did. Include:
- the figure in question and the two candidate values;
- which text you followed, and why (for example, "the NRS applies the gazetted text");
- the date of your decision and who advised you;
- what you will do if the re-gazetted text changes the figure.
Then set a reminder to check for the re-gazetted Acts each quarter. When they appear, compare the figures you depend on with the new text and update your note.
For the company income tax side of the reform, read company income tax in Nigeria from 2026, and for the broader picture of what the reform replaced, see Nigeria's tax reform: what changed. Start with your own turnover: if it falls between the disputed figures, book time with your adviser this month rather than at filing time.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
