Nigeria — Companies Income Tax (CIT) — Skill v1.0

Produced by OpenAccountants (openaccountants.com)

This skill is for informational purposes only and does not constitute tax, legal, or financial advice. All outputs must be reviewed and signed off by a Nigerian chartered tax practitioner (ICAN / ANAN / CITN) before filing or acting upon.

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Section 1 — Quick Reference

Field	Value
Country	Federal Republic of Nigeria
Tax	Companies Income Tax (CIT)
Currency	NGN (Naira) — ₦
Tax year	Accounting year of the company (any 12-month period; first/final years may be shorter)
Primary legislation (2025)	Companies Income Tax Act, Cap. C21 LFN 2004, as amended by Finance Acts 2019–2023
Primary legislation (2026+)	Nigeria Tax Act 2025 (NTA 2025) — signed by President Tinubu 26 June 2025; effective 1 January 2026
Tax authority	FIRS — Federal Inland Revenue Service
Filing portal	FIRS Tax Pro-Max (taxpromax.firs.gov.ng)
Annual return deadline	6 months after accounting year-end (Section 55 CITA / equivalent NTA 2025)
Payment	With return, or in instalments up to filing deadline (FIRS approval)
Bookkeeping retention	6 years (Section 63 CITA); align with NTA 2025 implementing regulations
Skill version	1.0
Validated by	Pending — sign-off by a CITN-licensed chartered tax practitioner

1.1 Rate Table

For assessment year 2025 (legacy CITA, accounting periods ending in 2025):

Company size	Definition	CIT rate
Small	Turnover ≤ ₦25M (CITA s.40 as amended Finance Act 2019)	0%
Medium	₦25M < Turnover ≤ ₦100M	20%
Large	Turnover > ₦100M	30%
Tertiary Education Tax (TET)	All companies except small	3% of assessable profit (Tertiary Education Trust Fund Act)
NITDA levy	Companies with turnover ≥ ₦100M in specified sectors	1% of profit before tax
NASENI levy	Companies with turnover ≥ ₦100M in specified sectors	0.25% of profit before tax
Police Trust Fund levy	All companies	0.005% of net profit

For assessment year 2026 onward (Nigeria Tax Act 2025):

Company size	Definition (NTA 2025)	CIT rate
Small	Turnover ≤ ₦100M AND fixed asset base ≤ ₦250M	0%
Medium	₦100M < Turnover ≤ ₦1B	20%
Large	Turnover > ₦1B	30% in 2026, transitioning to ~25% by 2029 via tax-credit mechanism per NTA 2025 transitional schedule
Development Levy (unified)	All non-small companies	2% of assessable profit — replaces TET, NITDA, NASENI, and Police Trust Fund levies
Minimum Effective Tax Rate (MET)	Multinational groups with consolidated revenue > €750M	15% floor (Pillar Two GloBE alignment)

TBC — verify under NTA 2025 final implementing regulations: the precise 2026-2029 large-company phasing schedule, the exact MET top-up mechanics, and the final Development Levy allocation formula are subject to FIRS implementing regulations expected late 2025 / early 2026.

1.2 Conservative Defaults

Ambiguity	Default
Accounting period spans 1 Jan 2026 (CITA-to-NTA transition)	Apportion on a daily basis; apply legacy rules to pre-2026 portion, NTA 2025 to post-2026 portion
Company size band unknown	Large (30% + 2% Development Levy)
Asset base unknown for NTA 2025 small-company test	Assume > ₦250M (small-company status denied)
Pillar Two MET applicability unclear	Treat as in-scope if any group entity is in a jurisdiction with consolidated revenue > €750M
Capital allowance claim unsupported	Disallow until asset-register evidence is produced
Loss carry-forward year unknown	Verify per-year schedule; treat oldest losses as expired under legacy 4-year limit if pre-Finance Act 2019
Pioneer status / IDITR relief uncertified	Apply standard rate; flag pending Industrial Inspectorate certificate
TIN status unknown	Halt — TIN is mandatory before filing

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Section 2 — Required Inputs and Refusal Catalogue

2.1 Required Inputs

Minimum viable — Audited or management financial statements (income statement, balance sheet) for the accounting year, prior-year CIT computation, TIN, accounting-year-end date, and confirmation of (i) turnover band, (ii) total fixed asset base, (iii) whether any group entity triggers Pillar Two scoping.

Recommended — Trial balance, general ledger, fixed-asset register (acquisition cost, date in use, location), schedule of capital additions and disposals, prior-year capital allowances brought forward, loss memo, tax credit certificates (WHT credit notes), donation receipts.

Ideal — Audited statements signed by a chartered accountant (ICAN), full WHT credit reconciliation, FIRS clearance certificates, group structure chart, transfer-pricing documentation if applicable, and prior year FIRS assessment notices.

HARD STOP if minimum is missing. Without financial statements and the prior-year return, no CIT computation may be produced.

2.2 Refusal Catalogue

R-NG-CIT-1 — Upstream oil & gas. Petroleum operations under the Petroleum Industry Act 2021 (PIA) — Hydrocarbon Tax (HT) and Companies Income Tax on midstream/downstream operations — require specialist handling. Escalate.

R-NG-CIT-2 — Banks, insurance, and pension funds. Sector-specific rules (CBN prudential disallowances, NAICOM rules, PenCom rules). Out of scope.

R-NG-CIT-3 — Free trade zones (NEPZA, OGFZA, Lekki FTZ, Calabar FTZ). Approved Enterprise status may carry CIT exemption with conditions. Out of scope; escalate to a zone-licensed advisor.

R-NG-CIT-4 — Pioneer status / Industrial Development Income Tax Relief (IDITR). Applications and ongoing eligibility are handled by NIPC, not by this skill. Apply standard CIT until pioneer certificate is in hand.

R-NG-CIT-5 — Transfer pricing controversy or APA. Disputes, MAP, or active TP audits are out of scope. Standard TP documentation under the Income Tax (Transfer Pricing) Regulations 2018 is mentioned but full computation is escalated.

R-NG-CIT-6 — Non-resident companies and digital services tax / Significant Economic Presence. Non-residents with SEP under Companies Income Tax (Significant Economic Presence) Order 2020 are out of scope.

R-NG-CIT-7 — Group / consolidated returns. Nigeria does not permit consolidated CIT returns; each company files separately. Group transfer-pricing implications are out of scope.

R-NG-CIT-8 — Active FIRS audit / assessment dispute. Companies with active FIRS Notice of Refusal to Amend (NORA), Tax Appeal Tribunal proceedings, or unpaid assessment notices must be escalated. Penalty and interest computations under Section 32 FIRS Establishment Act 2007 should be done by a chartered tax practitioner.

R-NG-CIT-9 — Cross-skill scope. Personal income tax → ng-income-tax. VAT → ng-vat-return / nigeria-vat. This skill is corporate income tax only.

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Section 3 — Tier 1 Rules

3.1 Charge to Tax — CITA s.9 (legacy) / NTA 2025

CIT is charged on the profits of any company accruing in, derived from, brought into, or received in Nigeria in respect of:

• Trade or business
• Rent or premiums from land or property
• Dividends, interest, royalties, discounts, charges, annuities
• Fees, dues, allowances for services rendered
• Any other annual profits or gains

NTA 2025 retains the same broad charging language with modernised drafting and explicit inclusion of digital and cross-border services.

3.2 Determining Company Size

Legacy 2025 thresholds (Finance Act 2019 / 2020 amendments to CITA):

Small  : Turnover ≤ ₦25,000,000           → 0% CIT, exempt from TET
Medium : ₦25M < Turnover ≤ ₦100,000,000   → 20% CIT
Large  : Turnover > ₦100,000,000          → 30% CIT

NTA 2025 thresholds (from 1 January 2026):

Small  : Turnover ≤ ₦100,000,000 AND fixed assets ≤ ₦250,000,000
         → 0% CIT, exempt from Development Levy

Medium : ₦100,000,000 < Turnover ≤ ₦1,000,000,000
         → 20% CIT + 2% Development Levy

Large  : Turnover > ₦1,000,000,000
         → 30% CIT phasing to ~25% by 2029 + 2% Development Levy

Important: under NTA 2025 the small-company test is dual (turnover AND asset base). Failing either limb forfeits 0% status. The threshold leap from ₦25M to ₦100M (turnover) and the new ₦250M asset cap is one of the headline reforms.

3.3 Large-Company Rate Phasing (NTA 2025)

Per NTA 2025 transitional provisions, the effective large-company CIT rate is reduced from 30% to approximately 25% through a phased tax credit between accounting years 2026 and 2029.

TBC — verify under NTA 2025 final implementing regulations. Indicative trajectory pending FIRS schedule:

Accounting year	Headline rate	Tax-credit reduction	Effective rate (approx.)
2026	30%	TBC	~28-30%
2027	30%	TBC	~27%
2028	30%	TBC	~26%
2029 onward	30%	TBC	~25%

Conservative default: until FIRS publishes the phasing schedule, compute at the headline rate stated for the year and label any reduction as "subject to NTA 2025 implementing regulations".

3.4 The Development Levy — NTA 2025

NTA 2025 consolidates four legacy levies — Tertiary Education Tax (TET, 3%), NITDA levy (1%), NASENI levy (0.25%), and Police Trust Fund levy (0.005%) — into a single 2% Development Levy on assessable profits of all non-small companies. The Levy is administered by FIRS and reported on the CIT return.

TBC — verify under NTA 2025 final implementing regulations: the precise allocation formula between TETFund, NITDA, NASENI, Defence Security Trust Fund, Police Trust Fund, and other beneficiaries; and the transition treatment for accounting years straddling 1 January 2026.

3.5 Pillar Two — Minimum Effective Tax Rate (MET)

Multinational enterprise groups with consolidated annual revenue exceeding €750 million in at least two of the preceding four years are subject to the 15% Minimum Effective Tax Rate (MET) introduced by NTA 2025 in alignment with the OECD/G20 Inclusive Framework Pillar Two GloBE Rules.

Mechanism: if the effective tax rate of the group's Nigerian operations falls below 15% after all credits, deductions, and incentives, a top-up tax brings the ETR to 15%. Pioneer status, free-trade-zone exemptions, and other tax holidays may be effectively neutralised within the MET scope.

TBC — verify under NTA 2025 final implementing regulations: the precise top-up mechanism (Domestic Top-up Tax / Qualified Domestic Minimum Top-up Tax — QDMTT), the Income Inclusion Rule (IIR), Undertaxed Payments Rule (UTPR) sequencing, and the carve-out / safe-harbour rules expected to mirror OECD model rules.

Conservative default: if any group entity has consolidated revenue > €750M, flag MET as in scope and request the group's Pillar Two computation.

3.6 Assessable Profit, Total Profit, and Chargeable Profit

The CIT computation proceeds in layers (CITA s.13 / NTA 2025 equivalents):

Adjusted Profit       = Accounting profit ± non-allowable / non-taxable items
Assessable Profit     = Adjusted Profit on preceding-year basis (current accounting period)
Total Profit          = Assessable Profit − Capital Allowances − Loss Relief
Tax Payable           = Applicable CIT rate × Total Profit
                        + Development Levy (2% × Assessable Profit, if not small)
                        + MET top-up (if applicable)
                        − WHT credits − Other allowable credits

3.7 Allowable Deductions — CITA s.24 / NTA 2025

Wholly, reasonably, exclusively, and necessarily (WREN) incurred in producing the profits. Examples:

• Interest on money borrowed and employed as capital (subject to thin-capitalisation: 30% EBITDA limit under Finance Act 2019, retained under NTA 2025)
• Rent of premises occupied for business
• Repairs of premises, plant, machinery (not improvements)
• Bad and doubtful debts (subject to specific provisioning rules)
• Pension and gratuity contributions to approved schemes
• Salaries, wages, allowances (subject to PAYE compliance)
• Donations to approved bodies (Fifth Schedule CITA; mirrored in NTA 2025)
• Research and development (with possible enhanced deduction under NTA 2025 — TBC)
• Bank charges, audit fees, professional fees

3.8 Non-Allowable Deductions — CITA s.27 / NTA 2025

The following are expressly disallowed:

• Capital expenditure (deduct via capital allowances, not as expenses)
• Domestic or private expenses
• Sum recoverable under any insurance or contract of indemnity
• Income tax itself, or any tax measured on profits
• Penalties or fines for breach of law
• Depreciation per accounts (replaced by capital allowances)
• Provisions for general reserves
• Donations not on the Fifth Schedule
• Expenses related to exempt income
• Excess interest beyond the 30% EBITDA thin-cap limit (Section 13A of the Finance Act 2019 amendments / NTA 2025 equivalent)

3.9 Capital Allowances — Second Schedule CITA / Sixth Schedule NTA 2025

Capital allowances replace book depreciation for tax. Rates per asset class:

Asset class	Initial allowance	Annual allowance
Building (industrial)	15%	10%
Building (non-industrial)	15%	10%
Furniture and fittings	25%	20%
Motor vehicle	50%	25%
Plant and machinery — agricultural	95%	nil (effectively 100% Year 1)
Plant and machinery — industrial	50%	25%
Plant and machinery — other	50%	25%
Computers (hardware)	50%	25%
Software	50%	25%
Research & development	95%	nil (full Year 1 for approved R&D)

TBC — verify under NTA 2025 Sixth Schedule final text whether any rate has been revised. Conservative default: apply the legacy CITA Second Schedule rates pending confirmation.

Restrictions:

• Capital allowances claimed in any year cannot reduce Total Profit below 1/3 of Assessable Profit for non-manufacturing companies (Section 31(2) CITA legacy). NTA 2025 — TBC whether this 2/3 cap is retained.
• Unused capital allowances carry forward indefinitely.
• Disposal triggers balancing charge / balancing allowance reconciliation.

3.10 Loss Relief

Legacy CITA: trade losses carried forward up to 4 years (extended to indefinite for non-insurance companies by Finance Act 2019). Insurance companies: 4-year cap (legacy).

NTA 2025: indefinite carry-forward for all companies, subject to anti-abuse rules (no carry-forward where ≥ 50% ownership change combined with major change in trade — TBC under final regulations).

No carry-back available.

3.11 Minimum Tax — CITA s.33 (legacy)

When a company has no total profit or total profit below the minimum-tax threshold, CITA s.33 (as amended by Finance Act 2019/2020) imposes a minimum tax of 0.5% of gross turnover less franked investment income.

Exemptions: small companies, companies in the first 4 calendar years of business, and companies engaged in agricultural trade.

NTA 2025: the minimum-tax regime is restructured. > TBC — verify under NTA 2025 final implementing regulations whether 0.5% of turnover is retained, replaced, or subsumed into the MET framework.

3.12 Withholding Tax (WHT) Credit

WHT suffered on income (interest, dividends, rent, royalties, fees) is creditable against CIT liability, subject to WHT credit notes from the deducting party. Excess WHT can be refunded or carried forward.

WHT on dividends paid out of profits already taxed at CIT — franked investment income — is not subject to further CIT (avoiding double taxation).

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Section 4 — Tier 2 Catalogue (Reviewer Judgement Required)

4.1 Pioneer Status / Industrial Development Income Tax Relief

Granted by the Nigerian Investment Promotion Commission (NIPC) under the Industrial Development (Income Tax Relief) Act. 5 years of tax holiday (3 + possible 2-year extension) for approved pioneer products and services.

Conservative default: apply standard CIT until the Pioneer Certificate is in hand. Note that under NTA 2025 Pillar Two MET, pioneer-status relief may be neutralised for large multinationals.

4.2 Export Expansion / Export Free Zones

Companies engaged in 100% export of manufactured goods may qualify for CIT exemption under the Nigerian Export Promotion Council (NEPC) regime. Free Zone Enterprises under NEPZA are out of scope (see refusal R-NG-CIT-3).

4.3 Real Estate Investment Companies (REICs)

REICs registered with SEC enjoy CIT exemption on rental income distributed to unit holders, subject to NTA 2025 conditions. Refer to specialist for full REIC computation.

4.4 Investment Allowance

An additional 10% one-off investment allowance on plant and equipment in addition to normal capital allowances under Section 32 CITA (legacy). > TBC — verify under NTA 2025 whether retained.

4.5 Thin Capitalisation — 30% EBITDA

Finance Act 2019 introduced an interest-deductibility limit of 30% of EBITDA on related-party interest. Excess interest carries forward up to 5 years. NTA 2025 retains the rule with confirmation expected in implementing regulations.

4.6 Transfer Pricing — Income Tax (Transfer Pricing) Regulations 2018

Companies with related-party transactions must apply the arm's-length principle and file:

• TP declaration (annual, with CIT return)
• Master File / Local File (where thresholds met)
• CbCR (consolidated revenue > €750M)

Full TP computation and controversy is out of scope (R-NG-CIT-5).

4.7 Donations

Only donations to organisations listed in the Fifth Schedule CITA / NTA 2025 equivalent are deductible. Cap: 10% of Total Profit before donation.

4.8 Foreign Tax Credit

Companies taxed on foreign-source income may claim relief by Tax Treaty (where Nigeria has one — currently with UK, France, Belgium, Netherlands, Canada, Pakistan, Romania, China, South Africa, etc.) or unilateral relief under CITA s.45. Credit limited to the Nigerian CIT attributable to that income.

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Section 5 — Worked Examples

All examples assume calendar accounting year ending 31 December 2025 (legacy CITA) unless stated.

5.1 Example A — Small Company (Legacy 2025)

Facts: ABC Ltd. Turnover ₦18,000,000. Accounting profit ₦4,500,000.

Small company test: Turnover ₦18M ≤ ₦25M  → Small
CIT                   : 0%        → ₦0
TET                   : Exempt    → ₦0
NITDA                 : Below ₦100M threshold → ₦0
Police Trust Fund     : 0.005% × accounting profit = ₦225 (de minimis)

Total tax payable     : ₦225 (effectively ₦0 in practice)

Filing: ABC Ltd still files its CIT return on Tax Pro-Max within 6 months of year-end.

5.2 Example B — Medium Company (Legacy 2025)

Facts: XYZ Ltd. Turnover ₦65,000,000. Adjusted profit ₦12,000,000. Capital allowances ₦2,000,000. No prior-year losses.

Assessable Profit     : ₦12,000,000
Less Capital Allow.   : (₦2,000,000)
Total Profit          : ₦10,000,000

CIT (20% × Total Profit)      : ₦2,000,000
TET (3% × Assessable Profit)   : ₦360,000
Police Trust Fund (de minimis) : ₦60

Less WHT credits              : (₦150,000) — WHT on professional fees

Net CIT payable               : ₦2,210,060

Filing: return + payment by 30 June 2026 (6 months after year-end).

5.3 Example C — Large Company (Legacy 2025)

Facts: Big Co Plc. Turnover ₦5,400,000,000. Adjusted profit ₦820,000,000. Capital allowances ₦180,000,000. Loss b/f ₦40,000,000. WHT credits ₦26,000,000. Not in NITDA / NASENI specified sectors.

Assessable Profit     : ₦820,000,000
Less Loss b/f         : (₦40,000,000)
Less Capital Allow.   : (₦180,000,000)
Total Profit          : ₦600,000,000

CIT (30% × Total Profit)         : ₦180,000,000
TET (3% × Assessable Profit)      : ₦24,600,000
Police Trust Fund (0.005%)        : ₦41,000  (on net profit)

Less WHT credits                  : (₦26,000,000)

Net CIT + levies payable          : ₦178,641,000

5.4 Example D — Large Company under NTA 2025 (Accounting Year 2026)

Facts: Big Co Plc, accounting year 1 January – 31 December 2026. Turnover ₦5,400,000,000. Adjusted profit ₦820,000,000. Capital allowances ₦180,000,000. Loss b/f ₦40,000,000. WHT credits ₦26,000,000. Not in a multinational group above €750M.

Company size (NTA 2025): Turnover > ₦1B  → Large

Assessable Profit     : ₦820,000,000
Less Loss b/f         : (₦40,000,000)
Less Capital Allow.   : (₦180,000,000)
Total Profit          : ₦600,000,000

CIT (30% × Total Profit, 2026 headline)   : ₦180,000,000
Development Levy (2% × Assessable Profit)  : ₦16,400,000   — replaces TET + NITDA + NASENI + PTF
MET top-up                                   : n/a (group revenue < €750M)

Less WHT credits                            : (₦26,000,000)
Less NTA 2025 transitional tax credit       : TBC under final regulations

Net CIT + Levy payable                      : ₦170,400,000 (before transitional credit)

Observations:

• Total tax burden shifts from ₦178.6M (legacy 2025) to ₦170.4M (NTA 2025) before the transitional tax credit phasing the effective rate down to ~25%.
• The Development Levy at 2% is lower than the combined legacy levies (~3.255% TET + NITDA + NASENI + PTF) for non-NITDA/NASENI sectors but higher than TET-only for companies that were not in the specified levy sectors.
• Verify final figures against FIRS implementing regulations.

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Section 6 — Filing and Payment Mechanics

6.1 Annual CIT Return — Form CIT

Component	Content
CIT computation	Adjusted profit → Assessable profit → Total profit → Tax payable
Capital allowance schedule	Per asset class, qualifying capital expenditure, allowances, TWDV
Loss memo	Year of loss, amount, utilisation, balance c/f
TET / Development Levy computation	Per applicable regime
WHT credit schedule	WHT certificates, deducting party, amount
Transfer pricing declaration	If applicable
Audited financial statements	Signed by ICAN-licensed auditor
Schedule of donations	Recipient, amount, Fifth Schedule reference

6.2 Filing Deadlines

Item	Deadline
Annual CIT return	Within 6 months after end of accounting year (Section 55(2) CITA / NTA 2025)
Self-assessment payment	With return; or by instalments approved by FIRS, last instalment by filing deadline
Provisional / advance returns	Companies on PAYE-style advance payments: see FIRS taxpayer category rules
Pillar Two GloBE Information Return	TBC under NTA 2025 implementing regulations (likely 15 months after FY-end, OECD-aligned)
TP returns (declaration, disclosure)	With CIT return
CbCR	12 months after end of reporting accounting year

Important distinction from personal income tax. Monthly PAYE handling for employees is a separate monthly obligation under the Personal Income Tax Act (PITA) and is covered in ng-income-tax. Companies are PAYE agents — they withhold and remit monthly by the 10th of the following month. This is administrative withholding, not CIT.

6.3 Filing Portal — FIRS Tax Pro-Max

All CIT returns are filed electronically via Tax Pro-Max (taxpromax.firs.gov.ng). The portal handles:

• Self-assessment CIT return
• TET / Development Levy
• WHT remittance and credit reconciliation
• VAT (separately, see ng-vat-return)
• TP declarations
• Tax clearance certificate (TCC) issuance

A valid Taxpayer Identification Number (TIN) issued by the Joint Tax Board / FIRS is mandatory.

6.4 Penalties and Interest

Infraction	Sanction
Late filing of CIT return	₦25,000 in first month + ₦5,000 each subsequent month (CITA / Finance Act updates)
Late payment	10% penalty + interest at CBN MPR + 5% per annum (Section 32 FIRS Establishment Act 2007)
Failure to deduct / remit WHT	10% of WHT due + interest
Incorrect return	Up to 100% of tax shortfall plus interest
Tax evasion / fraud	Fine up to ₦20,000 or 3× tax sought to be evaded, plus imprisonment up to 3 years

TBC — verify under NTA 2025 final implementing regulations for any revisions to penalty quanta and interest mechanics.

6.5 Tax Clearance Certificate (TCC)

A TCC is required for many official transactions (government contracts, loan applications, immigration matters). FIRS issues TCC after CIT compliance verification. Companies in the first 4 years may be issued a "new business" TCC.

6.6 Statute of Limitations

Standard period: 6 years from end of accounting year for FIRS to raise assessments (CITA s.66); no limit for fraud or wilful default.

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Section 7 — Conservative Defaults Summary

Item	Default
Company size band unknown	Large (30% + 2% Development Levy or legacy levies)
Asset base unknown (NTA 2025)	> ₦250M (small status denied)
Accounting period straddles 1 Jan 2026	Daily-apportion between CITA and NTA 2025
Pillar Two MET applicability uncertain	Treat as in scope if any group entity is in a group with revenue > €750M
Pioneer status uncertified	Apply standard rate
Capital allowance evidence missing	Disallow until asset register provided
Loss carry-forward year uncertain	Schedule per-year; expire pre-2019 losses at 4 years if pre-Finance Act 2019
Donation recipient not in Fifth Schedule	Disallow
Expense WREN test unclear	Disallow
WHT credit certificate missing	Disallow until certificate produced
Filing portal access uncertain	Confirm Tax Pro-Max enrolment before promising file dates
NTA 2025 figure not yet published	Label "TBC — verify under NTA 2025 final implementing regulations"

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Section 8 — Cross-References

Topic	Skill
Personal income tax / PAYE	ng-income-tax
VAT / value-added tax	ng-vat-return and nigeria-vat
Foundation principles	foundation
Intake checklist	intake
References / sources index	references

When a topic spans skills (e.g., employee BIK with CIT deductibility and PAYE consequences), address both — load the cross-skill before responding.

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Section 9 — Sources

Primary Legislation

• Nigeria Tax Act 2025 (NTA 2025) — signed by President Bola Ahmed Tinubu on 26 June 2025; effective 1 January 2026. Consolidates and replaces CITA, parts of PITA, VAT Act, Capital Gains Tax Act, and other tax statutes. Headline reforms: small-company threshold ₦100M turnover + ₦250M assets at 0%; medium 20%; large 30% phasing to ~25% by 2029; unified 2% Development Levy; 15% Minimum Effective Tax Rate for multinationals > €750M; indefinite loss carry-forward.
• Companies Income Tax Act (CITA), Cap. C21 LFN 2004, as amended — primary corporate tax statute for accounting years up to and including 31 December 2025.
• Tertiary Education Trust Fund (Establishment) Act 2011 — TET at 3% (subsumed into Development Levy under NTA 2025 from 2026).
• National Information Technology Development Agency Act 2007 — NITDA levy at 1% (subsumed into Development Levy).
• National Agency for Science and Engineering Infrastructure Act 1992 (as amended) — NASENI levy at 0.25% (subsumed).
• Nigeria Police Trust Fund (Establishment) Act 2019 — Police Trust Fund levy at 0.005% (subsumed).
• Industrial Development (Income Tax Relief) Act, Cap. I7 LFN 2004 — pioneer status.
• Personal Income Tax Act (PITA), Cap. P8 LFN 2004 as amended — PAYE agent obligations on companies.
• FIRS (Establishment) Act 2007 — penalties, interest, FIRS powers, Section 32 penalty regime.
• Petroleum Industry Act 2021 (PIA) — out of scope for this skill but referenced for boundary.

Finance Acts (amendments to CITA before NTA 2025)

• Finance Act 2019 — introduced 0%/20%/30% bands at ₦25M/₦100M thresholds; 30% EBITDA thin-cap; indefinite loss carry-forward (non-insurance).
• Finance Act 2020 — minimum-tax revisions (0.5% of turnover); commencement-period reform.
• Finance Act 2021 — digital services / SEP provisions for non-residents.
• Finance Act 2023 — further refinements.

Regulations

• Income Tax (Transfer Pricing) Regulations 2018 — TP documentation, declarations, CbCR.
• Companies Income Tax (Significant Economic Presence) Order 2020 — non-resident digital scope (out of scope here).
• NTA 2025 Implementing Regulations — pending publication by FIRS / Ministry of Finance late 2025 / early 2026.

Administrative Guidance

• FIRS Information Circulars — periodic guidance on capital allowances, donations, WHT, minimum tax, and TP.
• FIRS Tax Pro-Max portal documentation — taxpromax.firs.gov.ng.
• OECD/G20 Inclusive Framework Pillar Two GloBE Model Rules — basis for the 15% MET aligned by NTA 2025.

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PROHIBITIONS

• NEVER apply NTA 2025 rules to accounting periods ending before 1 January 2026 — they begin 1 January 2026.
• NEVER use the legacy ₦25M small-company turnover threshold for NTA 2025 periods — the threshold is ₦100M turnover AND ₦250M asset base.
• NEVER skip the dual-limb (turnover AND assets) test under NTA 2025 small-company definition.
• NEVER deduct income tax, TET, Development Levy, or any tax on profits as an expense.
• NEVER deduct book depreciation — use Sixth Schedule (NTA 2025) / Second Schedule (CITA) capital allowances.
• NEVER deduct donations to non-Fifth-Schedule bodies.
• NEVER allow interest expense above the 30% EBITDA thin-cap limit without flagging excess for carry-forward.
• NEVER claim pioneer status without an NIPC Pioneer Certificate in hand.
• NEVER apply the large-company transitional tax credit before FIRS publishes the schedule — label as "TBC".
• NEVER ignore the Pillar Two MET when group consolidated revenue > €750M.
• NEVER stack legacy TET + NITDA + NASENI + Police Trust Fund with the new 2% Development Levy — under NTA 2025 the Development Levy replaces them.
• NEVER skip TIN verification before filing.
• NEVER advise late filing or late payment as a strategy — 10% penalty + interest applies.
• NEVER present any NTA 2025 figure as definitive until cross-checked against published implementing regulations — label uncertain figures "TBC — verify under NTA 2025 final implementing regulations".
• NEVER conflate CIT with PAYE — PAYE is monthly under PITA and is a separate skill (ng-income-tax).

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Disclaimer

This skill and its outputs are for informational and computational purposes only and do not constitute tax, legal, or financial advice. All outputs must be reviewed and signed off by a Nigerian chartered tax practitioner (ICAN / ANAN / CITN) before filing or acting upon. NTA 2025 figures and mechanics labelled "TBC" must be verified against FIRS implementing regulations once published. The latest verified version of this skill is maintained at openaccountants.com.

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OpenAccountants — open-source accounting skills for AI

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This skill is a tool, not an engagement. Every taxpayer's situation is different, and the rules in the skill may not match your specific facts.

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