The Ultimate Value Added Tax Guide for Nigeria

1.  Introduction and How to Use This Guide

Value Added Tax (VAT) in Nigeria has entered a new era. With effect from 1 January 2026, the Value Added Tax Act (Cap. V1, LFN 2004) and the other legacy revenue statutes were repealed and consolidated into a single code — principally the Nigeria Tax Act 2025 (NTA) and the Nigeria Tax Administration Act 2025 (NTAA).[1] The tax authority itself was renamed: the Federal Inland Revenue Service (FIRS) became the Nigeria Revenue Service (NRS) under the Nigeria Revenue Service (Establishment) Act 2025.[2]

This guide is a practitioner's reference to the VAT rules that now govern both Nigerian businesses and foreign (non-resident) businesses that supply goods, services or intangibles to persons in Nigeria.

1.1  How the guide is organised

• •Part A — The framework and core rules (sections 2–5): the legal architecture, key concepts, scope and place of supply, and the rate structure (standard, zero-rated and exempt).
• •Part B — Compliance (sections 6–9): registration, the small-company exemption, obligations of Nigerian businesses, and the special regime for foreign/non-resident suppliers (including the now-repealed 2021 Simplified Compliance Regime).
• •Part C — Case law and sector treatment(sections 10–11): the Bolt, Ess-ay, NGX and Vodacom decisions, the VAT-collection controversy, and a sector-by-sector treatment table.
• •Part D — Practice (sections 12–17): worked examples, filing on Rev360, the e-invoicing/fiscalisation regime, penalties and interest, the direction of travel, and a compliance calendar.

“Reading note.  Statutory references are to the Nigeria Tax Act 2025 (NTA) or the Nigeria Tax Administration Act 2025 (NTAA) unless otherwise stated. All references appear as footnotes so the text can be read on its own. This guide is general information and not legal or tax advice; confirm positions with the NRS or a qualified adviser before acting.”

2.  The Legal Framework

Nigeria's tax laws were rationalised in 2025 into four principal statutes (the new Acts), supported by transition guidelines and administrative regulations:

• •Nigeria Tax Act 2025 (NTA): The substantive charging code. VAT is imposed by Chapter Six (sections 143–157); the VAT exemptions and zero-rating are in Part IV of Chapter Eight (sections 185–188).[3]
• •Nigeria Tax Administration Act 2025 (NTAA): The procedural code: registration, returns, assessment, refunds, enforcement, fiscalisation and penalties. VAT returns are governed by section 22, fiscalisation by section 23 and VAT refunds by section 56.[4]
• •Nigeria Revenue Service (Establishment) Act 2025: Establishes the NRS as successor to the FIRS.[5]
• •Joint Revenue Board (Establishment) Act 2025: Harmonises federal, state and local revenue administration and coordinates policy across the federation.[6]
• •General Transition Guidelines for the Tax Acts 2025: Made by the Minister of Finance under NTAA section 144 and NTA section 200 to govern the move from the repealed laws to the new Acts (see section 2.2).[7]
• •The repealed Value Added Tax Act (Cap. V1, LFN 2004) and the VAT Act (Modification) Order 2021 no longer have force; instruments and guidelines issued under them, including the 2021 Simplified Compliance Regime for non-resident suppliers a re spent, although their architecture has largely been carried into the NTA (as seen in section 150) and the guidelines the NRS may issue under it (see section 9).

2.1  What changed at a glance

2.2  Transition: which law applies to a given transaction

The Acts apply prospectively. The governing rule for transaction taxes such as VAT is date-of-supply based:

• •A supply of goods delivered or services rendered up to 31 December 2025 is subject to VAT under the repealed VAT Act, irrespective of when payment is made.
• •A supply occurring from 1 January 2026 is subject to VAT under the new Acts, except where payment was made in advance before commencement.
• •For contracts straddling both regimes, the new Acts apply only to the portion executed on or after 1 January 2026; sums received before commencement are taxed under the old law, sums received after under the new Acts.

“Conflict rule.  Where the new Acts conflict with any other tax law, the new Acts prevail; where two provisions of the new Acts are irreconcilable, the conflict is resolved in favour of the taxpayer.[8] ”

3. Core Concepts and Definitions

VAT is a consumption tax charged on the value added at each stage of the supply chain. A registered business charges output VAT on the taxable supplies it makes, recovers the input VAT it paid on its own taxable purchases, and remits the difference to the NRS. The following defined terms drive nearly every classification decision

Three classification buckets follow from these definitions and determine how an invoice is raised: standard-rated (7.5%), zero-rated (0%, VAT line still shown) and exempt (no VAT line at all). Section 5 of this Guide covers the difference and the full lists.[9]

4.  Scope, Place of Supply, Time and Value

4.1  Charge and territorial scope

Subject to the exemptions, VAT is paid on all taxable supplies in Nigeria.[10]

A supply is deemed to take place in Nigeria (and therefore subject to VAT) on a place-of-consumption basis as follows:[11]

• •Goods: Where they are physically present, imported into, assembled or installed in Nigeria at the time of supply; or where the beneficial owner of the rights is a taxable person in Nigeria and the goods/right are situated, registered or exercisable in Nigeria.
• •Services: Where the service is provided to and consumed by a person in Nigeria, regardless of whether it is rendered inside or outside Nigeria, or where the service is connected with immovable property located in Nigeria.
• •Incorporeal: Where the right is exploited by a person in (or usually resident in) Nigeria; where the right is registered in or assigned to a person in Nigeria; or where the incorporeal is connected with a tangible or immovable asset in Nigeria.

4.2  Time of supply

A taxable supply is deemed to occur at the earliest of: an invoice or receipt being issued; goods being delivered or made available; or payment becoming due to or received by the supplier. Special rules apply to connected-person supplies, rentals and periodic supplies, and instalment/milestone contracts.[12]

4.3  Value of supply and of imports

For a money consideration, the value is the amount which, with the VAT added, equals the consideration; for non-money or connected-person supplies, it is the open-market value. The value of imported taxable supplies is the price of the import plus duties, taxes and other charges (other than VAT) levied outside Nigeria or by reason of importation, plus commission, packing, transport and insurance up to the port or point of entry.[13]

5.  The Rate Structure: Standard, Zero-Rated and Exempt

VAT is charged on the value of all taxable supplies at 7.5% — the standard rate and the default unless a supply is specifically zero-rated or exempt. Only the Minister (by gazetted Order) or an Act of the National Assembly can vary the rate.[14]

“Zero-rated vs exempt — why it matters.  A zero-rated supply is taxable but at 0%: the business still shows a VAT line (at 0%) on the invoice and can recover its input VAT, including by refund. An exempt supply carries no VAT line at all (the invoice notes 'this supply is exempted from VAT') and input VAT attributable to it is not recoverable, rather it is expensed through the profit and loss account. Zero-rating favours the business; exemption breaks the input-VAT chain.[15] ”

5.1  Zero-rated supplies (0%)

The following are charged at zero percent under NTA section 186:[16]

• •Basic food items (staple agricultural/aquatic foods — grains, tubers, cooking oils, fish, meat, milk, fruit, vegetables, natural/table water, etc.).
• •All medical and pharmaceutical products, including approved medicinal herbal products.
• •Educational books and materials (for accredited institutions).
• •Fertilisers; locally produced agricultural chemicals, veterinary medicine and animal feeds.
• •Live cattle, goats, sheep and poultry; agricultural seeds and seedlings.
• •Electricity generated by Electricity Generating Companies (GENCOs) to the National Grid/ the Nigeria Bulk Electricity Trading Company (NBET), and transmitted by the Transmission Company of Nigeria (TCN) to Electricity Distribution Companies (DISCOs).
• •Medical services and medical equipment.
• •Tuition for nursery, primary, secondary or tertiary education.
• •Exported goods (excluding oil and gas), exported services and exported incorporeal property.

“In practice, electric vehicles and parts/semi-knocked-down units for assembling electric vehicles as treated as exempt, reflecting the reform's green-mobility incentive.[17] ”

In practice, electric vehicles and parts/semi-knocked-down units for assembling electric vehicles as treated as exempt, reflecting the reform's green-mobility incentive.[18]

5.2  Exempt supplies (no VAT)

The following are exempt from VAT under NTA section 185:[19]

• •Oil and gas exports; crude petroleum oil and feed gas for all processed gas.
• •Goods for humanitarian donor-funded projects (donor pays VAT then claims a refund).

• •Baby products; locally manufactured sanitary towels, pads or tampons.
• •Military hardware, arms, ammunition and locally manufactured uniforms for the armed forces, para-military and security agencies.

• •Shared passenger road-transport service (note: this does not cover ride-hailing — see section 10.1).
• •Purchase, hire, rental or lease of tractors, ploughs and other agricultural equipment.

• •Supplies consumed by approved entities in export-processing or free-trade zones (on approved activity).
• •Goods/services supplied to diplomatic missions and persons under the Diplomatic Immunities and Privileges Act (public-interest, not-for-profit).
• •Plays and performances by educational institutions as part of learning.
• •Land or building, including interest in land or building — i.e. the sale of land and rent do not carry VAT (see the Ess-ay and NGX cases, section 10).
• •Money, stakes or securities (including interest therein).

• •Government licences (e.g. petroleum mining leases and exploration licences), even on resale;
• •Assistive/disability devices (hearing aids, wheelchairs, braille materials).

“Insurance premiums and reimbursements.  Insurance premiums have historically and in practice not been subject to VAT, because in reality there is no value added. For reimbursements/refunds, a genuine reimbursement recovered at cost is generally not consideration for a supply and so falls outside VAT on first principles.[20] This is supported by case law in Brasoil Oil Services Company (Nigeria) Ltd (“Brasoil” or “the Appellant”) and the FIRS or “the Respondent”) – reported in the Tax Law Report of Nigeria (2016) Page 24.”

5.3. Currently Suspended VAT Regimes

The underlisted products were previously exempted from VAT under the VAT (Modification Order) 2021, and although that Order has now been repealed, Section 185 (2) of the NTA and the Eleventh Schedule of the NTA preserve their exemption until such as time as the Minister of Finance would revoke the exemption. The products are:

(a) petroleum products ;

(b) renewable energy equipment ;

(c) compressed natural gas (CNG) ;

(d) Liquefied Petroleum Gas (LPG) ; and

(e) other gaseous hydrocarbons.

"petroleum products" means automotive gas oil (AGO), aviation turbine kerosene (ATK), premium motor spirit (PMS), household kerosene (DPK) and locally produced liquefied petroleum gas (LPG) ;

"renewable energy equipment" means equipment used in producing renewable, green or low-carbon energy from renewable resources, such as sunlight, wind, the movement of water, and geothermal heat; and

"compressed natural gas" means fuel gas mainly composed of methane(CH4), compressed to less than 1% of the volume it occupies at standard atmospheric pressure.

6.  Registration and the Tax ID

Every taxable person must register with the NRS and obtain a Taxpayer Identification Number (Tax ID). VAT registration is automatic with the Tax ID — there is no separate VAT number.[21]

6.1  When the obligation starts — the commencement date

A business must register upon commencement of business, i.e. its first transaction, being the earliest of the date it: begins to market or first advertises its products/services; obtains an operating licence from a Nigerian regulator; makes its first sale or purchase; executes its first trading contract after incorporation; issues or receives its first invoice; delivers or receives its first consignment of goods; or first renders services to customers.

6.2  Foreign (non-resident) persons

A non-resident person that supplies taxable goods or services to any person in Nigeria, or derives income from Nigeria, must register and obtain a Tax ID. A non-resident deriving only passive income (dividend, interest, rent, royalties) from investment in Nigeria need not register but must provide information as prescribed by the NRS. The mechanics for non-residents are in section 9.[22]

6.3  Related Tax ID duties

• •One Tax ID per person — a person with a valid Tax ID may not obtain another; multiples must be reported for unification; a Tax ID is not transferable.
• •Changes in particulars (name, address, ownership of 5%+ shares, trustees/partners, sale/merger) must be notified within 30 days.
• •On temporary cessation, the Tax ID is suspended (dormant); on permanent cessation, the taxpayer must notify within 30 days and the NRS deregisters the Tax ID.
• •A Tax ID is a precondition for government contracts and for opening or operating bank, insurance or stock-broking accounts.[23]

7. The Small-Company Exemption

A small company, one with gross turnover of ₦100,000,000 or less per annum and total fixed assets not exceeding ₦250,000,000, must still register for a Tax ID (and thus VAT) but is not required to file VAT returns, charge VAT, or collect and remit it, unless it opts in by written notice to the NRS.[24]

• •Professional-services firms are never small companies — regardless of turnover. 'Professional services' means services requiring specialised knowledge, skills and qualifications (e.g. consulting, planning or support services), excluding artisans and vocational services.
• •Opt-in to recover input VAT — a small company that wants to track and claim input-VAT credits/refunds must file VAT returns notwithstanding the exemption.
• •Records still required — even when exempt, a small company must keep sufficient transaction records to establish its tax liability.

• •Threshold-testing carve-outs — in testing the ₦100m turnover threshold, the value of a capital asset disposal and of supplies made solely because the business is being sold or permanently ceasing are excluded.

“Transition trap.  Under the repealed laws the small-company threshold was turnover ≤ ₦25m; under the new Acts it is turnover ≤ ₦100m and assets ≤ ₦250m. A company small under the old test may be treated differently for basis periods spanning 2025–2026.[25]”

8.  Compliance for Nigerian Businesses

Every business other than a small company must run the full VAT cycle: issue a tax invoice, collect the VAT, compute the net tax, remit it, file returns, and keep records.

8.1  The tax invoice

Invoices must be sequentially numbered and, for a standard or zero-rated supply, show VAT (at 7.5% or 0%). An exempt supply shows no VAT line but bears the note 'this supply is exempted from VAT'. A compliant tax invoice contains:[26]

• •Supplier's Tax ID;
• •A sequential invoice number;
• •Supplier's name and address;
• •Supplier's incorporation/business-registration number (as applicable).
• •Date of supply
• •Name of the purchaser/client;

• •The gross amount of the transaction and ;
• •The VAT charged and the rate.

The NRS may direct any taxable person to adopt electronic invoicing on at least 30 days' notice — the bridge to the fiscalisation regime in section 14 of this Guide.[27]

8.2  Withholding VAT: When the customer remits instead of the supplier

The general rule is that the supplier collects output VAT from the customer. The exception is where the customer is an appointed withholding-VAT (WVAT) agent: the agent withholds the VAT and remits it directly to the NRS, on or before the 14th day of the following month, with a schedule (supplier name, Tax ID, address, invoice number, gross amount, VAT and period). Appointed agents in practice include:[28]

• •Federal, State and Local governments and their ministries, departments and agencies (MDAs).
• •Deposit Money Banks;
• •Oil and gas companies.
• •Specific telecommunication companies*

Where a supplier issues an invoice without VAT, the NRS may direct the recipient to self-account for the VAT and remit it.[29]

“Oil and Gas companies are currently not named in the NTA as WVAT agents, but the VAT Act before the repeal included them and we envisage that the NRS will continue the tradition of their appointment by leveraging their power under S. 154 (1) (b) of the NTA to appoint them given how successful their appointment proved in terms of collecting VAT revenue for the government.
*Deposit Money Banks and Telecommunication Companies on the other hand were appointed via an FIRS public notice of 7th November 2022 and their appointment continued until the NTA was enacted.”

8.3  Input VAT, apportionment and net tax

Net VAT payable = output VAT − deductible input VAT. Input VAT is now deductible on goods for resale, raw materials, services and fixed assets acquired for consumption, use or supply in making taxable supplies (including zero-rated). Two limits apply:[30]

• •Apportionment: Where input tax relates to both taxable and non-taxable (exempt) supplies, only the proportion attributable to taxable supplies is deductible.
• •Five-year limit: Input tax is deductible within five years after the end of the tax period in which it was incurred, and only in respect of supplies made from the commencement of the NTA.

8.4  Refunds of excess input VAT

Where input VAT exceeds output VAT, the business may either carry the excess forward as a credit against future output VAT, or apply for a refund. A refund request must be made within 12 months of the transaction, and the NRS must refund (or set off) within 30 days of a valid request. Imported goods must have their VAT paid before clearing.[31]

8.5  Filing and payment deadlines

• •Regular VAT returns: Filed on or before the 21st day of each month for the previous month's transactions, showing input tax paid, output tax collected and VAT payable.
• •Withholding-VAT returns: Filed (and the VAT remitted) by the 14th day of the month following the transaction, with the prescribed schedule.
• •Payment: Net VAT is remitted through NRS-approved channels (e.g. Remita, Interswitch, Flutterwave and collecting banks). An extension of the filing period does not extend the time to pay.[32]

8.6  Domestic compliance checklist

• •Confirm registration and a valid Tax ID (VAT is automatic with the Tax ID).
• •Classify every product/service line: standard (7.5%), zero-rated (0%) or exempt.
• •Issue sequentially numbered tax invoices with all eight required particulars.
• •Determine whether the customer is a WVAT agent (MDA, bank, oil & gas, platform).
• •Track input VAT on goods, services and fixed assets; apportion for mixed use.
• •File and pay regular VAT by the 21st; file/remit withheld VAT by the 14th.
• •Retain full transaction records to support the return and any refund claim.
• •Prepare for e-invoicing/fiscalisation (MBS) — see section 14 of the Guide.

9.  Foreign and Non-Resident Businesses Selling to Nigeria

Nigeria taxes on a place-of-consumption basis, so a supply consumed or utilised in Nigeria is taxable even if the supplier is entirely offshore. The NTA now codifies the framework the FIRS previously ran through the 2021 Simplified Compliance Regime.

9.1  The statutory rule (NTA section 150)

• •Register and charge: A non-resident that makes taxable supplies to Nigeria must register for tax and include VAT on its invoices for all taxable supplies.
• •Reverse charge: Where a non-resident supplies from outside Nigeria to a person in Nigeria, the Nigerian recipient withholds the VAT and remits it to the NRS.
• •Appointed collection agent: The NRS may, by notice, appoint any person (including a non-resident supplier or a digital platform) to collect and remit the VAT. Once an appointed person is in the chain, the Nigerian recipient need not withhold — unless the appointed person fails to collect.

10.  Worked Examples

Figures are illustrative and assume the supplier is not a small company. VAT is 7.5%.

Example 1 — Net VAT for a domestic manufacturer

A furniture maker sells taxable goods worth ₦10,000,000 in July and buys raw materials worth ₦4,000,000 (VAT ₦300,000).

• •Output VAT: 7.5% × ₦10,000,000 = ₦750,000.
• •Input VAT: ₦300,000 (raw materials used for taxable supplies).
• •Net VAT payable: ₦750,000 − ₦300,000 = ₦450,000, filed and paid by 21 August.

Example 2 — Input-VAT apportionment (mixed supplies)

A company earns ₦8,000,000 of taxable revenue and ₦2,000,000 of exempt rental income (total ₦10,000,000). It incurs ₦500,000 of input VAT on general overheads used for both.

• •Taxable proportion: ₦8,000,000 ÷ ₦10,000,000 = 80%.
• •Deductible input VAT: 80% × ₦500,000 = ₦400,000.
• •Non-deductible (relates to exempt rent): ₦100,000 — a cost to the business (NTA section 155(4)(a)).

Example 3 — Withholding-VAT agent

An Agency of the Federal Government receives a ₦20,000,000 consultancy invoice from a professional firm, VAT ₦1,500,000.

• •The agent withholds the ₦1,500,000 VAT and remits it to the NRS by the 14th of the following month, with a schedule; it pays the firm the ₦20,000,000 less withholding tax.
• •The consultant reports the ₦1,500,000 as output VAT but takes credit for the VAT withheld, so it is not double-charged. not process payment but earns a commission collects the VAT through the same mechanism it uses to collect its commission.

11. Filing on Rev360

Filing and payment have moved from the FIRS TaxProMax portal to Rev360, the NRS one-stop digital platform that brings registration, filing, payment, tax credits, dispute resolution and compliance management under a single system. Rev360 went live on 30 April 2026.[34]

• •Migration from TaxProMax: Gradual, with both platforms running during a transition. Existing profiles, prior returns, payment history, withholding-tax credits, outstanding balances and compliance records migrate automatically; taxpayers do not re-register.
• •One portal, many taxes: VAT, companies income tax, withholding taxes and others are filed through Rev360. The taxpayer logs in, selects the tax type, completes an online form or uploads the prescribed Excel template, and submits electronically.
• •VAT classification codes: On Rev360 each sale line is classified: 0 = Vatable at 7.5%, 1 = Exempt, 2 = Zero-rated; the VAT is then computed automatically from the classification.[35]
• •Deadlines are unchanged.  Rev360 is the channel; the statutory dates still apply — regular VAT by the 21st, withheld VAT by the 14th (sections 8.5 and 17).

12.  The E-Invoicing (Fiscalisation) Regime

The reform's most operationally significant change is mandatory electronic invoicing / fiscalisation. The NTA requires a taxable person making taxable supplies to implement the fiscalisation system deployed by the NRS, and the NTAA requires use of the Electronic Fiscal System (EFS) for recording and reporting all supplies once deployed.[36]

12.1  The Merchant-Buyer Solution (MBS)

The NRS platform is the Merchant-Buyer Solution (MBS), which enables real-time generation, validation, storage and exchange of invoices. For B2B and B2G supplies, the supplier submits the invoice to the NRS for pre-clearance; a cleared invoice receives an Invoice Reference Number (IRN) and a cryptographic stamp (QR) that marks it as authentic before it is provided to the buyer. The mandate covers all VAT-registered suppliers — domestic and foreign — across B2B, B2G and B2C transactions.[37]

12.2  Timeline and standards

• •Large taxpayers (annual turnover over ₦5 billion) — mandatory e-invoicing registration was moved from 1 August 2025 to 1 November 2025, with a Go Live date in June 2026.
• •Medium VAT-registered businesses — mandatory compliance from 1 July 2026 with compliance enforcement to commence on 1 January 2027.
• •Emerging taxpayers - mandatory compliance from 1 July 2027 with compliance enforcement to commence on 1 January 2028

13.  Penalties and Interest

The NTAA imposes administrative penalties (and, for some defaults, criminal liability) for VAT-related failures:

14.  Compliance Calendar and Key Numbers

“Disclaimer.  This guide is a general reference on Nigerian VAT under the Nigeria Tax Act 2025 and the Nigeria Tax Administration Act 2025 as at July 2026, drawing on TaxStreem’s internal VAT Engine rule books, the Acts and transition guidelines, publicly reported case law, and NRS platform information. It is not legal or tax advice, and administrative details (thresholds, deadlines, platforms and case outcomes on appeal) may change. Confirm the current position with the Nigeria Revenue Service or a qualified tax adviser before acting.”

[1]General Transition Guidelines, paras. 5, 10 and 10.2.1–10.2.2.

[2]Nigeria Tax Act 2025, Chapter Six (ss. 143–157) 'Value Added Tax'; Chapter Eight, Part IV (ss. 185–188) 'Exemption from Value Added Tax'.

[3]Nigeria Tax Administration Act 2025, s. 22 (Returns for VAT), s. 23 (VAT Fiscalisation System), s. 56 (VAT Refund), ss. 100–124 (administrative penalties).

[4]Nigeria Revenue Service (Establishment) Act 2025.

[5]Joint Revenue Board (Establishment) Act 2025; see also General Transition Guidelines, para. 17(3).

[6]General Transition Guidelines for the Tax Acts 2025, issued by the Honourable Minister of Finance and Coordinating Minister of the Economy (Taiwo Oyedele), made pursuant to NTAA s. 144 and NTA s. 200.

[7]Nigeria Tax Act 2025, repeals schedule (repealing inter alia the VAT Act, Cap. V1, LFN 2004 and the Value Added Tax Act (Modification) Order 2021). Savings for validly-made administrative decisions: General Transition Guidelines, para. 21.

[8]General Transition Guidelines, para. 14(1) and (3).

[9] 'Standard VAT Rules', 'Zero-Rated VAT Supplies' and 'VAT Exempt Supplies'; mirrored in NTA ss. 147, 185–186.

[10]Nigeria Tax Act 2025, s. 144 (Charge of VAT); s. 143 (Imposition).

[11]Nigeria Tax Act 2025, s. 145 (Taxable supplies). This codifies the destination/place-of-consumption principle previously read into the repealed Act by the courts (see the Vodacom decision, section 10).

[12]Nigeria Tax Act 2025, s. 146. For instalment or milestone billing, VAT applies to each payment or invoice as it falls due, regardless of when the project concludes: s. 146(3);

[13]Nigeria Tax Act 2025, ss. 148 (value of taxable supplies) and 149 (value of imported goods);

[14]Nigeria Tax Act 2025, s. 147 (Rate of VAT — 7.5%).

[15] 'Zero-Rated VAT Supplies' and 'VAT Exempt Supplies'; NTA ss. 185–186 and s. 155(4) (apportionment)

[16]Nigeria Tax Act 2025, s. 186 (Taxable supplies chargeable at zero percent).

[17]Per now repealed VAT (Modification) Order, 2021 but preserved under Section 185 (2) of the NTA

[18]Per now repealed VAT (Modification) Order, 2021 but preserved under Section 185 (2) of the NTA

[19]Nigeria Tax Act 2025, s. 185(1) (Exempt supplies).

[20] Neither NTA s. 185 nor s. 186 lists these items expressly.

[21]Nigeria Tax Administration Act 2025, s. 4 (every taxable person shall register and obtain a Tax ID);

[22]Nigeria Tax Administration Act 2025, s. 6 (non-resident person); Nigeria Tax Act 2025, s. 150 (taxable supply of non-residents);

[23]Nigeria Tax Administration Act 2025, ss. 7 (issuance), 8 (use of Tax ID — contracts and financial accounts), 9 (notification of change within 30 days) and 10 (suspension, deregistration and cancellation).

[24]Nigeria Tax Act 2025, definition of 'small company' (turnover ≤ ₦100,000,000 and fixed assets ≤ ₦250,000,000); Nigeria Tax Administration Act 2025, s. 22(4)–(6) (small business exempt from monthly VAT returns; may opt out of the exemption by written notice; must file once it ceases to be small).

[25]General Transition Guidelines, para. 20 (definition of 'small company' — ₦25m under repealed laws; ₦100m turnover and ₦250m assets under the new Acts) and para. 10.1.2(3).

[26]Nigeria Tax Act 2025, s. 152 (VAT invoice — sequential numbering and required particulars);.

[27]Nigeria Tax Act 2025, s. 152(4).

[28]Nigeria Tax Act 2025, s. 154 (collection of VAT by persons other than the supplier; remittance by the 14th day of the following month with a schedule);

[29]Nigeria Tax Act 2025, s. 154(2).

[30]Nigeria Tax Act 2025, s. 155(4) (input tax on taxable supplies, including services and fixed assets, deductible to the extent used for taxable supplies); This broadens the narrower input-VAT scope applied by the FIRS under the repealed regime.

[31]Nigeria Tax Act 2025, s. 155(1)–(3); Nigeria Tax Administration Act 2025, s. 56 (refund request within 12 months; refund or set-off within 30 days). Note: a false or fictitious refund claim attracts a 100% penalty plus interest — NTAA s. 122.

[32]Nigeria Tax Administration Act 2025, s. 22(1)–(3) (VAT returns by the 21st day of the following month) and s. 22(2) (extension of filing does not extend time to pay); Nigeria Tax Act 2025, s. 154(4) (withheld VAT remitted by the 14th day);

[33]Nigeria Tax Act 2025, s. 150(1)–(8) (taxable supply of non-residents: registration and charge; recipient withholding; appointment of collection agents; commission mechanism; appointment of a representative; no further VAT at import where already collected).

34]'Nigeria Revenue Service to Launch Rev360 Platform…', Proshare; Forvis Mazars, 'REV 360: Nigeria's New Digital Tax Platform by NRS'; Rev360 launched 30 April 2026 and formally unveiled 10 June 2026. NRS self-service portal: https://selfservice.nrs.gov.ng/.

[35]'TaxProMax to Rev360: Complete Migration Guide' and 'Rev360 NRS Portal: Login, Registration & Filing Guide', nrsportal.ng;

[36]Nigeria Tax Act 2025, ss. 152(4) (NRS may direct electronic invoicing on 30 days' notice) and 157 (fiscalisation of supplies for VAT — electronic devices, software and secure networks for e-invoicing and data transfer); Nigeria Tax Administration Act 2025, s. 23 (VAT Fiscalisation System — use of the EFS; maintain accurate records; NRS to specify the system and transition).

[37]NRS Merchant-Buyer Solution, https://einvoice.nrs.gov.ng/.