The Organised Private Sector of Nigeria (OPSN) has raised strong concerns over what it describes as an attempt by the Nigeria Revenue Service (NRS) to apply provisions of the newly enacted Nigeria Tax Act, 2025, and the Nigeria Tax Administration Act, 2025, to financial transactions and corporate income already concluded before the law officially takes effect.
In a public notice jointly issued by leading business and industry groups, including the Manufacturers Association of Nigeria (MAN), NACCIMA, NECA, NASME and NASSI, the OPSN warned that such an approach could undermine legal certainty, investor confidence and established principles of tax administration.
The group argued that while the new tax reforms are scheduled to commence on 1 January 2026, applying them to Corporate Income Tax returns covering the 2025 fiscal year amounts to retroactive enforcement, which they say is inconsistent with standard legal practice unless explicitly stated in law.
OPSN leaders questioned whether income earned, contracts executed and accounting periods completed before the commencement date can lawfully be subjected to new tax rules. They maintained that tax laws are ordinarily applied prospectively, not retrospectively, to protect legitimate expectations and ensure stability in the business environment.
The statement, signed by the directors-general of the participating organisations, emphasized that while the private sector supports tax reform efforts, implementation must align strictly with constitutional and statutory provisions to avoid disputes and economic disruption.
The group further noted that previous attempts at dialogue with the revenue authorities had not sufficiently addressed their legal concerns, prompting the public intervention.
They called on the Nigeria Revenue Service to suspend any administrative measures that apply the new tax laws to 2025 accounting periods and to clarify that Corporate Income Tax filings for periods ending on or before 31 December 2025 should continue under existing legislation.
OPSN also urged the Presidency and relevant government agencies to intervene to ensure clarity, consistency and smooth implementation of the tax reforms, warning that ambiguity in enforcement could affect investment decisions and business planning.
Efforts to obtain an official response from the Nigeria Revenue Service were unsuccessful at the time of filing this report.
