Nigeria — Return Assembly (Capstone) — Skill v1.0

CRITICAL EXECUTION DIRECTIVE — READ FIRST

When this skill is invoked, the user has already passed through intake and the relevant content skills. They want their finished Nigerian return working paper. Execute all steps without pausing for permission.

Specifically:

• Do NOT ask "do you want me to assemble the full package". The user asked for the return. Produce it.
• Do NOT re-interrogate the user about residency, TIN, RC number, or business structure — intake already captured this; trust the upstream packages.
• Do NOT pause between reconciliation steps to check in. Run all cross-checks in sequence; flag failures in the reviewer brief and continue.
• Self-checks are targets, not blockers. If a check fails, note it under "Reviewer Attention Flags" and continue.
• Do NOT submit anything to FIRS Tax Pro-Max or any State IRS portal. This skill produces a working paper plus filing instructions. A Chartered Accountant in Nigeria (ICAN or ANAN member) must review, and the taxpayer (or authorised filer) submits via the relevant portal.

If you feel the urge to ask "how should I proceed", pick the most defensible path, proceed, and flag the decision for the reviewer.

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What this file is

The final capstone skill for Nigerian annual tax returns. It consumes the outputs of every other Nigeria skill and assembles a single unified working paper covering either:

• Personal Income Tax (PIT) Form A — annual return for resident individuals (including sole proprietors), filed with the relevant State Internal Revenue Service (SIRS / LIRS for Lagos, FCT-IRS for Abuja, etc.) under the Personal Income Tax Act (PITA) as amended
• Companies Income Tax (CIT) Self-Assessment Return — annual return for resident companies (RC), filed with the Federal Inland Revenue Service (FIRS) under the Companies Income Tax Act (CITA) as amended, supplemented by Tertiary Education Tax (TET) under the Tertiary Education Trust Fund Act, and where applicable the new Development Levy introduced by the Nigeria Tax Act 2025

The output is a reviewer-ready package: line-by-line return working paper, cross-skill reconciliation table, payment instructions (Tax Pro-Max billing reference and Remita RRR), filing instructions for federal and state portals, reviewer checklist, and taxpayer action list.

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Section 1 — Quick reference

Field	Value
Country	Federal Republic of Nigeria
Federal tax authority	Federal Inland Revenue Service (FIRS) — soon transitioning to Nigeria Revenue Service (NRS) under NTA 2025
State tax authorities	36 State Internal Revenue Services + FCT-IRS (Lagos = LIRS, Rivers = RIRS, etc.)
Federal filing portal	FIRS Tax Pro-Max (https://taxpromax.firs.gov.ng)
Payment platform	Remita (https://www.remita.net) — Treasury Single Account (TSA) consolidation
Currency	NGN (Nigerian Naira / ₦)
Tax year	Calendar year for individuals (1 January – 31 December); accounting year-end for companies (commonly 31 December, but any 12-month period)
Current tax year	2025 (filing window for Dec 2025 year-ends opens January 2026)
Individual return	PIT — Form A (annual income declaration), filed with State IRS
Corporate return	CIT Self-Assessment Return (Tax Pro-Max electronic form), filed with FIRS
Employer annual return	Form H1 (annual PAYE reconciliation), filed with State IRS
VAT return	FIRS VAT Form 002 (monthly)
Individual filing deadline	31 March 2026 (PITA Section 41 — 90 days after year-end)
Employer Form H1 deadline	31 January 2026 (PITA Section 81 — 31 January following year-end)
CIT deadline	6 months after FYE — for 31 December 2025 year-end, due 30 June 2026 (CITA Section 55)
VAT monthly deadline	21st of following month (VAT Act Section 14)
Confirmation receipt	Tax Pro-Max acknowledgement (Federal); SIRS portal acknowledgement (State); Remita RRR / e-receipt for payment
Governing law	Companies Income Tax Act (CITA, Cap C21 LFN 2004 as amended); Personal Income Tax Act (PITA, Cap P8 LFN 2004 as amended); Value Added Tax Act (Cap V1 LFN 2004 as amended); Capital Gains Tax Act (Cap C1 LFN 2004 as amended); Tertiary Education Trust Fund Act 2011; FIRS Establishment Act 2007; Nigeria Tax Act 2025 (NTA 2025) — assented June 2025, key provisions effective 1 January 2026
Skill version	1.0
Validated by	Pending — requires sign-off by Chartered Accountant in Nigeria (ICAN — Institute of Chartered Accountants of Nigeria, or ANAN — Association of National Accountants of Nigeria)

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Section 2 — Required inputs from upstream skills

The assembly skill does not recompute anything. It expects structured outputs from the following upstream skills. If an upstream skill did not run, the assembly notes the gap and continues with available data.

2.1 Individual return (PIT Form A) — inputs

Upstream skill	Output consumed	Where it lands on Form A
ng-personal-income-tax	Chargeable income computation: gross income, allowable deductions, consolidated relief allowance (CRA), reliefs, PIT due at graduated rates	Form A Parts B, C, D
ng-paye	Employment income from employer Form H1; PAYE already deducted at source via monthly Form G	Form A Part B (employment income); credit for PAYE in Part D
ng-statutory-deductions	Pension (8% employee contribution), NHF (2.5%), NHIS, life assurance premium — all reducing chargeable income	Form A Part C (reliefs and allowances)
ng-wht	WHT credit notes received as a recipient (e.g., 5%/10% on professional fees, rent, royalties, dividends, interest)	Form A Part D (tax credits)
ng-cgt	Capital gains tax computation on chargeable assets disposed of in the year (10% rate under CGTA)	Filed separately on CGT return; cross-referenced in Form A net worth schedule
ng-vat	If sole proprietor is VAT-registered: monthly VAT return position; cross-check of turnover only	Cross-check, not on Form A directly
ng-payroll	Sole proprietor as employer: PAYE for staff, pension remittance, NHF — supports the H1 the proprietor files	Separate Form H1; supports Form A Part C if proprietor's own pension contribution exists
ng-formation	Business registration evidence: CAC BN number (sole proprietor) or RC number (if incorporated and individual is director); TIN	Identity section of Form A

2.2 Corporate return (CIT Self-Assessment) — inputs

Upstream skill	Output consumed	Where it lands on the CIT return
ng-cit	Adjusted profit, capital allowances claimed, taxable profit, CIT at applicable rate (30% large, 20% medium, 0% small under CITA + Finance Acts; NTA 2025 changes apply from FY 2026), Tertiary Education Tax at 3% of assessable profits, Development Levy where applicable	Tax Pro-Max CIT return Schedules
ng-paye	Employee payroll cost classification; PAYE remittance evidence	Operating expenses section; supports Form H1 filing
ng-statutory-deductions	Employer pension (10%), NHF, NHIS, ITF (1% of payroll), NSITF (1% of payroll) — all deductible business expenses	Operating expenses; ITF/NSITF compliance certificates required for CAC and tax clearance
ng-wht	WHT deducted from company on dividends/interest received and on contracts (credit notes); WHT the company remitted as a withholding agent (compliance only)	Schedule of WHT credits; reconciliation to monthly remittances
ng-cgt	CGT on chargeable assets disposed in the year (10% rate)	Separate CGT return; cross-referenced
ng-vat	Monthly VAT return position; VAT paid is not creditable against CIT; non-recoverable input VAT is a cost in the P&L	Cross-check; non-recoverable input VAT flows into P&L expenses
ng-payroll	Full payroll cost classification; supports Form H1 and monthly Form G	Operating expenses; supports H1
ng-formation	CAC registration evidence (RC number); FIRS TIN; SCUML if applicable; ITF / NSITF compliance certificates	Identity section of CIT return; required for Tax Clearance Certificate

2.3 Intake-required identifiers

Identifier	Required for
TIN (Tax Identification Number) — 10-digit, FIRS-issued for companies, JTB/State-issued for individuals (unified TIN under NTA 2025)	All returns
RC Number (Registration Number) — issued by Corporate Affairs Commission (CAC) for companies	CIT return
BN Number (Business Name) — issued by CAC for sole proprietors / partnerships	PIT return if trading under a business name
NIN (National Identity Number) — NIMC-issued, now linked to individual TIN	PIT return
Employer Code — issued by State IRS for PAYE / Form G filing	All payroll filings
State of Residence — determines which State IRS has jurisdiction for PIT (PITA First Schedule "place of residence" rule)	PIT return — critical, drives filing portal
LGA (Local Government Area) of residence	PIT return supplementary
Pension PIN (PenCom-issued RSA PIN)	Pension reliefs and remittance evidence

If any identifier is missing, the assembly skill flags it as "Needs Input" and produces the working paper with placeholders rather than halting.

2.4 Federal vs State coordination

Nigeria has a bifurcated tax administration:

• Federal (FIRS): CIT, TET, VAT, WHT on companies, CGT on companies, Stamp Duties on certain instruments, Petroleum Profits Tax (out of scope), Development Levy (NTA 2025).
• State (SIRS): PIT including PAYE remittance, CGT on individuals, business premises levy, development levies (state), road tax, withholding tax on individuals (5% of contract payments to individuals).

The capstone produces separate filing packs for federal and state. A single individual sole proprietor may have BOTH a federal VAT obligation (FIRS) AND a PIT obligation (State IRS). The assembly cross-references both.

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Section 3 — Tax computation reconciliation

The assembly skill verifies that numbers from the upstream skills are mutually consistent. If a cross-check fails by more than ₦1,000, the discrepancy is raised in the reviewer brief — never silently rounded.

Cross-check 1 — Revenue reconciliation (turnover ties across skills)

Source	Figure	Rule
Bookkeeping / management accounts gross revenue	Total operating revenue	Anchor figure
ng-vat annual taxable supplies	Sum of monthly VAT 002 output Box	Must reconcile to bookkeeping revenue ± permitted timing differences and VAT-exempt revenue
ng-cit (corporates) / ng-personal-income-tax (individuals) gross income	Top line of fiscal computation	Must equal bookkeeping ± fiscal-vs-accounting adjustments
ng-wht (as recipient) — contract values from WHT credit notes received	Implicit gross from WHT credits ÷ WHT rate	Should reconcile to a subset of bookkeeping revenue

If mismatch: Likely causes are (i) VAT-exempt or zero-rated supplies not in VAT output, (ii) cash vs accrual timing, (iii) intra-group eliminations, (iv) revenue subject to final WHT (rent, royalties to individuals) not in the same bucket.

Cross-check 2 — Tax credits add up correctly

For individuals (Form A):

Line	Source skill	Description
PAYE deducted by employer(s)	ng-paye (Form H1 from employer)	Credit
WHT on professional fees / rent / royalties / dividends / interest received	ng-wht (credit notes)	Credit
Provisional tax paid (instalments under PITA Section 44)	ng-personal-income-tax	Credit
Foreign tax credit (where DTT exists or unilateral relief under PITA Section 38)	ng-personal-income-tax	Credit, capped at Nigerian PIT on same income

For corporates (CIT):

Line	Source skill	Description
WHT suffered on contracts, rent, dividends, interest (FIRS / SIRS credit notes)	ng-wht	Credit
Provisional tax / advance CIT paid	ng-cit	Credit
Foreign tax credit (CITA Section 44 — DTT or unilateral relief)	ng-cit	Credit, capped
Excess Dividend Tax (EDT) prior-year offset under CITA Section 19	ng-cit	If applicable

Rule: Total credits cannot exceed tax payable for refund purposes unless excess is supported by valid FIRS/SIRS credit notes with verifiable serial numbers. WHT credit notes have a 6-year shelf life under Section 78A CITA (introduced by Finance Act 2019), but practical FIRS verification is shorter — flag any credit note older than 3 years for confirmation.

Cross-check 3 — PAYE reconciliation between annual H1 and monthly Form G

Item	Source	Rule
Sum of monthly Form G PAYE remitted (Jan–Dec 2025)	ng-paye / ng-payroll	Should equal total PAYE in Form H1
Form H1 total PAYE	ng-paye	Annual reconciliation
Form H1 due date	Fixed	31 January 2026
Late-filing penalty	PITA Section 81(3)	₦500,000 (company) or ₦50,000 (individual employer) per month

If mismatch: Likely cause is mid-year joiners/leavers, bonus / 13th-month paid in December not captured in monthly remittance, or PAYE on benefits-in-kind only recognised at year-end.

Cross-check 4 — Statutory deductions remittance compliance

Item	Source	Rule
Pension — 18% combined (10% employer + 8% employee) of monthly emoluments	ng-statutory-deductions	Must be remitted to RSA PFA within 7 working days of salary payment (PRA 2014 Section 11(3))
NHF — 2.5% of basic salary (employees earning ≥ ₦3,000/month)	ng-statutory-deductions	Remitted monthly to FMBN
NHIS — varies by scheme	ng-statutory-deductions	Monthly
ITF — 1% of total annual payroll (employers with ≥ 5 employees or ≥ ₦50M turnover)	ng-statutory-deductions	Due by 1 April 2026
NSITF — 1% of total annual payroll (employers ≥ 5 employees)	ng-statutory-deductions	Monthly within 14 days; annual reconciliation

Compliance certificates required for FIRS Tax Clearance Certificate (TCC):

• ITF Compliance Certificate
• NSITF Compliance Certificate
• PenCom Compliance Certificate
• NHF Compliance Certificate

Missing any of these blocks TCC issuance, which in turn blocks government contracts, visa applications, and bank loans. Flag any missing certificate in the reviewer brief.

Cross-check 5 — WHT compliance as a withholding agent

If the taxpayer (especially a company) is required to withhold tax on its suppliers:

Item	Source	Rule
WHT on contracts paid (5% companies, 5%/10% individuals)	ng-wht	Remitted monthly by 21st of following month (FIRS for companies; State IRS for individuals)
WHT on rent paid (10%)	ng-wht	Monthly
WHT on professional fees (10% individuals, 5% companies)	ng-wht	Monthly
WHT on dividends, interest, royalties (10%, sometimes final)	ng-wht	Monthly
WHT credit notes issued to suppliers	ng-wht	Must be issued promptly; failure exposes principal to disallowance of expense (Section 81 CITA / Section 73 PITA)

Rule: Withholding is the entity's obligation, not its own tax credit. Failure to withhold can result in (a) penalty of ₦500,000 (company) or ₦50,000 (individual) plus 10% of unremitted amount, and (b) disallowance of the underlying expense. Flag any apparent failure for the reviewer.

Cross-check 6 — VAT-to-CIT/PIT consistency (for VAT-registered taxpayers)

Item	Source	Rule
Output VAT (7.5% on taxable supplies)	ng-vat	NOT income — held in trust for FIRS
Input VAT recoverable	ng-vat	NOT a cost in fiscal P&L — netted against output
Input VAT non-recoverable (e.g., on overhead before VAT Modification Order rules)	ng-vat	IS a cost in fiscal P&L
VAT on imported services (reverse charge per Finance Act 2020)	ng-vat	Self-account; reverse charge entries must reconcile

If inconsistency: An expense net of VAT in the P&L while the VAT was also not claimed on the VAT return means the VAT is lost. Flag for reviewer.

Cross-check 7 — Capital allowances (companies) and CGT (both)

Item	Source	Rule
Capital allowances claimed in CIT computation	ng-cit	Cannot exceed 66 2/3% of assessable profits for non-manufacturing companies (CITA Section 31 / Second Schedule); manufacturing companies have no cap
Tax Written Down Value (TWDV) roll-forward	ng-cit	Opening TWDV + additions − initial + annual allowances = closing TWDV
CGT on chargeable assets disposed	ng-cgt	10% on net gain; CGTA Section 2; principal private residence and certain shares exempt
Roll-over relief claimed	ng-cgt	Confirm CGTA Section 32 conditions met

Note: NTA 2025 introduces revised capital allowance rates and an updated definition of "qualifying capital expenditure" effective 1 January 2026 — this does NOT affect FY 2025 computations but must be flagged in 2026 planning.

Cross-check 8 — Tolerance discipline

For every cross-check above, the threshold is ₦1,000. If a difference is between ₦1,000 and ₦100,000, document the variance and proceed with a reviewer flag. If above ₦100,000, raise as "Needs Input" — the reviewer should resolve before sign-off.

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Section 4 — Working paper template: individual PIT Form A

Form A is the annual income declaration filed with the relevant State Internal Revenue Service (the SIRS of the taxpayer's "place of residence" as defined in PITA First Schedule). For Lagos residents this is LIRS; FCT residents file with FCT-IRS; Rivers with RIRS, etc.

4.1 Form A — line-by-line

Part	Line	Description	Source
Identity	TIN, NIN, name, BN (if applicable), address, state, LGA, marital status, dependants, employer details	All	Intake
A. Gross Income	1	Employment income (salary, wages, bonus, 13th-month, BIK)	ng-paye
	2	Trade, business, profession (sole-proprietor net profit per accounts)	ng-personal-income-tax
	3	Rental income (gross)	ng-personal-income-tax (rental subject to 10% WHT often final)
	4	Dividends, interest, royalties (gross, before WHT)	ng-personal-income-tax
	5	Pensions and annuities	ng-personal-income-tax
	6	Other income	ng-personal-income-tax
	7	Total Gross Income	Sum 1–6
B. Allowable Deductions	8	Trade / business allowable expenses	ng-personal-income-tax
	9	Capital allowances on business assets	ng-personal-income-tax
	10	Other allowable deductions (interest on owner-occupied mortgage etc.)	ng-personal-income-tax
	11	Total Deductions	Sum
C. Reliefs & Allowances	12	Consolidated Relief Allowance (CRA) — higher of ₦200,000 or 1% of gross income, plus 20% of gross income (PITA Sixth Schedule as amended by Finance Act 2020)	ng-personal-income-tax
	13	Pension contribution (8% employee or self-employed equivalent)	ng-statutory-deductions
	14	NHF (2.5%)	ng-statutory-deductions
	15	Life assurance premium	ng-statutory-deductions
	16	NHIS	ng-statutory-deductions
	17	Total Reliefs	Sum
D. Chargeable Income	18	Line 7 − Line 11 − Line 17	Computed
E. Tax Computation	19	Apply graduated PIT rates (7% / 11% / 15% / 19% / 21% / 24% — PITA Sixth Schedule) to Line 18	ng-personal-income-tax
F. Tax Credits	20	PAYE deducted at source (per Form H1 from employer)	ng-paye
	21	WHT suffered (per credit notes)	ng-wht
	22	Provisional tax paid (instalments)	ng-personal-income-tax
	23	Foreign tax credit (capped)	ng-personal-income-tax
	24	Total Credits	Sum
G. Tax Payable / Refundable	25	Line 19 − Line 24 (positive = balance due; negative = refund / carry-forward)	Computed

4.2 Supporting schedules

Schedule	Title	When used
Schedule 1	Statement of Assets & Liabilities (Net Worth Statement)	Mandatory for high-net-worth and discretionary for others — required by LIRS for income > ₦25M
Schedule 2	Business income detailed P&L (sole-proprietor)	If business income on Line 2
Schedule 3	Capital allowances schedule (additions, disposals, TWDV)	If business assets
Schedule 4	Rental income property-by-property breakdown	If rental income
Schedule 5	WHT credit notes register (serial number, payer, date, amount)	If WHT credits claimed
Schedule 6	Foreign income & foreign tax credit working	If foreign income

4.3 NTA 2025 transitional note for individuals

The Nigeria Tax Act 2025 (assented June 2025) revises the PIT regime from 1 January 2026, including:

• New graduated PIT rates (0% / 15% / 18% / 21% / 23% / 25% per draft as published — confirm at FY 2026 filing time)
• New tax-free threshold of ₦800,000 annual chargeable income (replacing CRA structure)
• Rent relief of up to ₦200,000 per year
• Consolidation of the unified TIN regime
• None of these apply to the 2025 return. Flag in the 2026 planning section.

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Section 5 — Working paper template: corporate CIT Self-Assessment

Filed via FIRS Tax Pro-Max (https://taxpromax.firs.gov.ng). Tax Pro-Max generates an assessment notice, billing reference, and Remita RRR for payment.

5.1 CIT Self-Assessment — line-by-line

Section	Line	Description	Source
Identity	RC No., TIN, name, registered office, year of assessment, accounting period, principal activity	All	Intake
A. Profit/Loss per Accounts	1	Turnover (revenue)	Bookkeeping
	2	Cost of sales	Bookkeeping
	3	Gross profit	Computed
	4	Operating expenses	Bookkeeping
	5	Other income (non-operating)	Bookkeeping
	6	Profit/(Loss) per accounts	Computed
B. Tax Adjustments	7	Add: depreciation per accounts	ng-cit (disallowed; replaced by capital allowances)
	8	Add: disallowable expenses (donations not approved, entertainment, fines/penalties, general provisions, etc. per CITA Section 27)	ng-cit
	9	Less: non-taxable income (dividends from Nigerian companies — franked, certain exempt)	ng-cit
	10	Less: capital gains taxed separately under CGTA	ng-cgt
	11	Assessable Profit	Computed
C. Capital Allowances	12	Initial allowances on qualifying capital expenditure	ng-cit
	13	Annual allowances	ng-cit
	14	Investment allowances (where applicable)	ng-cit
	15	Balancing allowances / (charges)	ng-cit
	16	Total Capital Allowances (capped at 66 2/3% of assessable profit for non-manufacturing; no cap for manufacturing per CITA Second Schedule)	Computed
D. Loss Relief	17	Brought-forward losses utilised (indefinite carry-forward under CITA Section 31, post-Finance Act 2019)	ng-cit
E. Total Profit (Taxable Profit)	18	Line 11 − Line 16 − Line 17	Computed
F. Tax Charge	19	CIT rate applied: 0% (small company — turnover ≤ ₦25M); 20% (medium — ₦25M < turnover ≤ ₦100M); 30% (large — turnover > ₦100M) per CITA Section 40 as amended by Finance Act 2019/2020	ng-cit
	20	CIT liability	Line 18 × rate
	21	Tertiary Education Tax (TET) at 3% of assessable profit (TET Act as amended by Finance Act 2023 — rate increased from 2.5% to 2.5% then to 3.0% under Finance Act 2023; confirm rate effective for FY 2025)	ng-cit
	22	Development Levy (NTA 2025) — not applicable for FY 2025; effective FY 2026 onward at 4% of assessable profit consolidating TET, NITDA, NASENI levies	n/a for 2025
	23	NITDA Levy 1% (companies with turnover ≥ ₦100M, IT-related sectors)	ng-cit
	24	NASENI Levy 0.25% (specified sectors)	ng-cit
	25	Police Trust Fund Levy 0.005% of net profit	ng-cit
	26	Total Federal Tax Liability	Sum 20–25
G. Tax Credits	27	WHT suffered (credit notes)	ng-wht
	28	Advance / provisional CIT paid	ng-cit
	29	Foreign tax credit	ng-cit
	30	Total Credits	Sum
H. Net Tax Payable	31	Line 26 − Line 30	Computed
I. Minimum Tax Check	32	Minimum tax under CITA Section 33 (where company has no/insufficient tax payable): 0.5% of gross turnover less franked investment income, for non-exempt companies. NTA 2025 introduces Minimum Effective Tax Rate (MEFR) of 15% for large groups effective 2026 (out of scope for 2025)	ng-cit

5.2 Supporting schedules (Tax Pro-Max attachments)

Schedule	Title	When used
Schedule 1	Audited Financial Statements (Statement of Profit or Loss, Statement of Financial Position, Statement of Cash Flows, Notes) — signed by directors + auditors (ICAN/ANAN)	Always (CITA Section 55 + CAMA 2020)
Schedule 2	Detailed Tax Computation	Always
Schedule 3	Capital Allowances Schedule (per asset class, with TWDV roll-forward)	Always if fixed assets
Schedule 4	Loss Relief Schedule (YOA-by-YOA brought-forward losses)	If losses
Schedule 5	WHT credit notes register	If WHT credits claimed
Schedule 6	Related-party transactions / Transfer Pricing Declaration Form (FIRS TP Regulations 2018)	If related-party transactions exist
Schedule 7	Country-by-Country Reporting notification (multinationals with consolidated revenue ≥ ₦160 billion)	If MNE
Schedule 8	Donations schedule (specified Sixth Schedule beneficiaries only)	If charitable donations
Schedule 9	Compliance certificates (ITF, NSITF, PenCom, NHF)	Always for TCC

5.3 Tertiary Education Tax detail

TET is computed at 3% of assessable profit (Line 11 in 5.1), not total profit. It applies to all Nigerian-resident companies regardless of size (no small-company exemption — confirmed by Finance Act 2023). TET is administered by FIRS and paid alongside CIT through Tax Pro-Max.

5.4 NTA 2025 transitional note for companies

The Nigeria Tax Act 2025 (effective 1 January 2026) introduces sweeping changes that do NOT apply to FY 2025 but must be flagged for FY 2026:

• Development Levy at 4% consolidating TET (3%), NITDA (1%), and NASENI (0.25%) into a single levy
• Small company threshold raised to ₦100M annual turnover (currently ₦25M)
• CIT rate reduced to 25% for large companies (down from 30%)
• Minimum Effective Tax Rate (MEFR) of 15% for multinational groups with ≥ €750M consolidated revenue (Pillar Two adoption)
• VAT rate to remain at 7.5% in 2026 (NTA 2025 left the rate untouched after political pushback on proposed increase)
• Nigeria Revenue Service (NRS) replaces FIRS as the federal tax authority
• Unified TIN regime
• Digital services tax updates

The 2026 planning section of the reviewer brief flags every NTA 2025 item materially affecting the taxpayer.

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Section 6 — Payment instructions: Tax Pro-Max, Remita, Treasury Single Account

Nigerian tax payments flow through the Treasury Single Account (TSA) via the Remita payment platform. The taxpayer logs into Tax Pro-Max, the system generates an assessment and an associated billing reference / Remita Retrieval Reference (RRR), the taxpayer pays the RRR via bank channel (any commercial bank, internet banking, mobile banking, USSD, or POS), and Remita issues a payment receipt that auto-feeds back to Tax Pro-Max as payment evidence.

6.1 Tax types and FIRS / State channels

Tax	Authority	Portal / Form	Payment channel
CIT	FIRS (federal)	Tax Pro-Max — CIT Self-Assessment	Remita RRR → bank → TSA
TET	FIRS	Tax Pro-Max — TET module	Same
VAT	FIRS	Tax Pro-Max — VAT Form 002 (monthly)	Same
WHT (companies)	FIRS	Tax Pro-Max — WHT module	Same
PAYE	State IRS (LIRS, FCT-IRS, RIRS, etc.)	State portal (e.g., eTax LIRS) — Form G monthly, Form H1 annual	State-specific Remita / portal payment
PIT (individual annual)	State IRS	State portal — Form A	Same
WHT (individuals)	State IRS	State portal	Same
CGT (companies)	FIRS	Tax Pro-Max	Same
CGT (individuals)	State IRS	State portal	Same
ITF Levy	ITF	ITF portal	Direct
NSITF	NSITF	NSITF portal	Direct
Pension	PenCom (regulator) → PFA (custodian)	RSA via PFA	Bank transfer to PFA custodian
NHF	FMBN	FMBN portal	Direct

6.2 Tax Pro-Max → Remita → TSA flow

1. Log into Tax Pro-Max with TIN + password (or FIRS-issued digital certificate for high-volume filers)
2. Select tax type (CIT, TET, VAT, WHT) and period (year of assessment / month)
3. Enter computation OR upload XML / spreadsheet (Tax Pro-Max accepts bulk upload templates)
4. Submit — system generates Assessment Notice and Billing Reference Number (BRN)
5. Tax Pro-Max generates Remita RRR (15-digit) tied to the BRN
6. Pay the RRR via:
   • Any commercial bank teller (cash/cheque/bank transfer)
   • Internet banking (most Tier-1 banks integrate Remita)
   • Mobile banking app
   • USSD (Remita short code per bank)
   • POS at FIRS office
7. Bank confirms payment → Remita issues e-receipt with Remita Transaction Reference (RTR) + Tax Pro-Max payment evidence
8. Tax Pro-Max marks the assessment as settled; the corresponding return becomes filed (or filing is now actionable if payment was required first)

6.3 Tax Pro-Max payment timing relative to filing

Payment	Due date	Filing reference
CIT — FY ending 31 December 2025	30 June 2026 (CITA Section 55)	Self-Assessment Return
TET — FY ending 31 December 2025	30 June 2026 (paid with CIT)	Within CIT return
VAT monthly (December 2025)	21 January 2026	VAT 002
WHT monthly (December 2025 deductions)	21 January 2026	WHT schedule
PAYE monthly (December 2025)	10 January 2026 (PITA Section 81; 10th of following month)	Form G
PIT annual (individual)	31 March 2026 (PITA Section 41 — 90 days after year-end)	Form A
Employer annual PAYE reconciliation	31 January 2026	Form H1
ITF Levy (FY 2025)	1 April 2026	ITF annual return
NSITF (December 2025)	14 January 2026; annual reconciliation also due	Monthly
Pension (December 2025 salary)	Within 7 working days of salary payment	RSA contribution schedule

Rule: For CIT, FIRS practice is to require payment evidence (RTR) to be uploaded before the Self-Assessment Return is treated as accepted. Plan to settle BEFORE the formal submission step — or in two instalments per CITA Section 77 (one with provisional return at 3 months, balance with final return).

6.4 Provisional / instalment CIT under CITA Section 77

CITA Section 77 permits payment in instalments:

• Option 1 (Single payment): Pay full CIT liability on filing date (or on or before due date if filing earlier)
• Option 2 (Instalments): Up to 6 monthly instalments with FIRS approval; first instalment with the return, subsequent monthly. 2% interest applies on outstanding balance.

For provisional tax (where statute requires), the company pays an estimate within 3 months of year-end and trues up at filing. FIRS practice is increasingly tolerant of single-payment-at-filing where the company is a "good standing" taxpayer.

6.5 Payment evidence to retain

Document	Issued by	Retain for
Remita RRR	Tax Pro-Max	Until settled
Remita e-Receipt (RTR)	Remita	Indefinite — proof of payment
Tax Pro-Max Payment Confirmation	FIRS	Indefinite
Tax Clearance Certificate (TCC)	FIRS / State IRS	12-month validity; renew annually
Compliance Certificates (ITF, NSITF, PenCom, NHF)	Respective agencies	12-month validity each

---

Section 7 — Filing instructions

7.1 Federal (FIRS) filings via Tax Pro-Max

Channel	Description	Best for
Tax Pro-Max Web — Direct Entry	Fill the return directly in browser	Small / medium taxpayers
Tax Pro-Max Web — Bulk Upload	Upload FIRS-template Excel / XML	Larger taxpayers, multi-line schedules
Tax Pro-Max API	Direct integration for ERP / accounting software	Big-4 / multinational filers

Submission steps (CIT example):

1. Prepare — finalise audited accounts, sign-off by directors and external auditors (ICAN-registered)
2. Log into Tax Pro-Max (TIN + password)
3. Navigate to CIT → File Return → Year of Assessment 2026 (relating to FY 2025)
4. Enter / upload computation; attach audited financial statements (PDF), tax computation (PDF/XLSX), capital allowances schedule, and compliance certificates
5. Validate — Tax Pro-Max runs arithmetic checks; resolve errors
6. Submit return → system generates Assessment Notice + Remita RRR
7. Pay the RRR (or set up instalment plan if applicable)
8. After payment, retrieve filed-and-paid acknowledgement — this is proof of compliance and is the basis for Tax Clearance Certificate (TCC) application
9. Apply for TCC for the year (separate Tax Pro-Max workflow)

7.2 State (SIRS) filings — example: LIRS eTax

Each State IRS operates its own portal; LIRS is the largest. General pattern:

1. Log into State IRS portal (e.g., https://etax.lirs.net for Lagos)
2. Navigate to Annual Returns → Form A (Individuals) or Annual Returns → Form H1 (Employers)
3. Enter income, deductions, reliefs, credits
4. Upload supporting documents (payslips, WHT credit notes, business accounts for sole proprietors)
5. Submit → portal generates Assessment Notice + Remita RRR for any balance
6. Pay via Remita
7. Retrieve filing acknowledgement → basis for State TCC

7.3 Deadlines summary (tax year 2025 / year of assessment 2026)

Filer type	Return	Authority	Deadline
Individual (resident)	Form A (annual PIT)	State IRS	31 March 2026 (PITA Section 41)
Employer	Form H1 (annual PAYE reconciliation)	State IRS	31 January 2026 (PITA Section 81)
Employer	Form G (monthly PAYE)	State IRS	10th of following month
Company	CIT Self-Assessment (FY 31 Dec 2025)	FIRS	30 June 2026 (CITA Section 55 — 6 months after FYE)
Company	TET (with CIT)	FIRS	30 June 2026
VAT-registered taxpayer	VAT Form 002 (monthly)	FIRS	21st of following month
Withholding agent	WHT monthly schedule	FIRS (companies) / State IRS (individuals)	21st of following month (FIRS) / 10th (State)
Sole proprietor	Form A + Schedule 2 (business income)	State IRS	31 March 2026
ITF	Annual contribution	ITF	1 April 2026
NSITF	Annual reconciliation	NSITF	31 March 2026

7.4 Late filing penalties

Filer	Tax	Penalty	Basis
Company	CIT late filing	₦25,000 first month + ₦5,000 per additional month	CITA Section 55(3)
Company	CIT late payment	10% of unpaid tax + interest at CBN MPR + 5% per annum	CITA Section 85
Company	TET late	Same as CIT proportionally	TET Act
Employer	Form H1 late	₦500,000 (corporate) / ₦50,000 (individual employer)	PITA Section 81(3)
Individual	Form A late	₦5,000 + ₦100 per day of default	PITA Section 94
VAT-registered	VAT late filing	₦50,000 first month + ₦25,000 per additional month	VAT Act Section 19 (Finance Act 2020)
WHT	Failure to deduct/remit	10% of unremitted amount + interest at CBN MPR + 5%	CITA Section 81 / PITA Section 73

7.5 Filing-versus-payment ordering

Unlike some jurisdictions, in Nigerian practice the assessment is generated FROM the filed return, then the Remita RRR is settled. There is no true "pay first, then file" — but for the return to be treated as substantively complete, the matching payment must be made before the deadline. Late payment penalties accrue independently of late filing penalties.

---

Section 8 — Working paper structure for the credentialed reviewer

The reviewer is a Chartered Accountant in Nigeria — ICAN (Institute of Chartered Accountants of Nigeria) or ANAN (Association of National Accountants of Nigeria) member, and (for tax-specific opinions) potentially a CITN (Chartered Institute of Taxation of Nigeria) member. The reviewer brief is a single markdown file the reviewer reads before sign-off.

# Complete Return Package — [Taxpayer Name] — Year of Assessment 2026 (FY 2025)

## Executive Summary
- Filing entity: [Individual / Sole Proprietor / Company (Small/Medium/Large per CITA)]
- TIN: [10-digit]
- RC No. / BN No.: [if applicable]
- State of Residence (individuals): [for SIRS jurisdiction]
- Tax regime: [PIT graduated rates / CIT 0% / CIT 20% / CIT 30%]
- VAT status: [Registered / Below threshold]
- Returns to be filed:
  - [ ] Form A (PIT) — State IRS — due 31 March 2026
  - [ ] Form H1 (PAYE annual) — State IRS — due 31 January 2026
  - [ ] CIT Self-Assessment — FIRS Tax Pro-Max — due 30 June 2026
  - [ ] TET — within CIT return
  - [ ] VAT 002 December — FIRS — due 21 January 2026
- Total federal tax liability: ₦X
- Total state tax liability: ₦X
- Total credits: ₦X
- Net payable / refundable: ₦X
- TCC application due: [date]

## Federal Tax Computation (CIT + TET + Levies)
[From ng-cit]
- Audited P&L reconciliation
- Tax adjustments schedule (disallowables, exempt income)
- Capital allowances schedule with TWDV roll-forward
- Loss relief schedule
- CIT at applicable rate (0% / 20% / 30%)
- TET at 3% of assessable profit
- NITDA, NASENI, Police Trust Fund Levy (where applicable)

## State Tax Computation (PIT / PAYE)
[From ng-personal-income-tax, ng-paye]
- Form A line-by-line
- Form H1 employer reconciliation
- State of residence determination (PITA First Schedule)

## Statutory Deductions Compliance
[From ng-statutory-deductions]
- Pension remittance log (PFA confirmations) — within 7 working days
- NHF monthly remittance
- ITF annual compliance certificate status
- NSITF annual compliance certificate status
- NHIS / NHIA scheme status
- PenCom compliance certificate status

## Withholding Tax (WHT)
[From ng-wht]
- As withholding agent: monthly remittance schedule, credit notes issued to suppliers
- As recipient: WHT credit notes received, serial number register, ageing analysis

## VAT
[From ng-vat]
- Monthly VAT 002 summary for 2025
- Output VAT, input VAT recoverable, net VAT remitted
- Cross-check to bookkeeping turnover

## Capital Gains Tax
[From ng-cgt]
- Disposals schedule
- Net chargeable gains at 10% CGT rate
- Roll-over relief claims

## Payroll
[From ng-payroll]
- Annual payroll summary
- BIK computation
- Payroll reconciliation to general ledger

## Formation / Compliance Identity
[From ng-formation]
- CAC RC / BN status
- TIN status (FIRS / JTB unified)
- ITF / NSITF / PenCom / NHF certificate status

## Cross-Skill Reconciliation
- Revenue reconciliation: [pass/fail]
- Tax credits add up: [pass/fail]
- PAYE annual H1 vs monthly G: [pass/fail]
- Statutory deductions remitted on time: [pass/fail]
- WHT agent compliance: [pass/fail]
- VAT-to-income consistency: [pass/fail]
- Capital allowances within Section 31 cap (non-manufacturing): [pass/fail]

## Reviewer Attention Flags
- Items requiring ICAN / CITN confirmation
- Disallowable expenses borderline (entertainment, donations not on Sixth Schedule, general provisions)
- Related-party transactions (TP Regulations 2018 — local file due with return)
- WHT credit notes older than 3 years (ageing risk)
- Missing compliance certificates blocking TCC
- Minimum tax check under CITA Section 33
- Excess Dividend Tax (EDT) risk under CITA Section 19
- State of residence ambiguity for PIT (multi-state employee)

## Positions Taken
[List with legislation citations]
- e.g., "Small company exemption applied — turnover ₦X ≤ ₦25M, CITA Section 40 as amended by Finance Act 2019"
- e.g., "TET at 3% of assessable profit per Finance Act 2023 amendment to TET Act"
- e.g., "Donations of ₦X to [Sixth Schedule beneficiary] — CITA Sixth Schedule, item Y"
- e.g., "Capital allowances claimed at full rate, no Section 31 cap (manufacturing exception)"

## Planning Notes for 2026 (NTA 2025 impact)
- Development Levy at 4% replaces TET/NITDA/NASENI from 1 Jan 2026
- Small company threshold rising to ₦100M turnover
- CIT large-company rate dropping to 25%
- MEFR of 15% for MNE groups (if applicable)
- New PIT rates and ₦800,000 tax-free threshold for individuals
- Rent relief up to ₦200,000 for individuals
- Unified TIN regime full rollout
- FIRS → Nigeria Revenue Service (NRS) rebrand
- Consolidated Nigeria Tax Account view in Tax Pro-Max from 1 Jan 2026

---

Section 9 — Tax computation summary (PIT or CIT bottom line)

This section is the single "headline" block the reviewer and taxpayer read first.

9.1 Individual headline block

# PIT 2025 — Headline (₦)

Gross Income:                      X
Less: Allowable deductions:        (X)
Less: Reliefs (CRA + statutory):   (X)
= Chargeable Income:               X

PIT at graduated rates:            X
Less: PAYE deducted:               (X)
Less: WHT credits:                 (X)
Less: Provisional tax:             (X)
= Net PIT payable / (refundable):  X / (X)

Filing: Form A, State IRS [name], due 31 March 2026
Payment: Remita RRR generated post-filing

9.2 Corporate headline block

# CIT 2025 — Headline (₦) — Year of Assessment 2026

Turnover:                          X
Profit per accounts:               X
Add: Disallowables:                X
Less: Exempt income:               (X)
= Assessable Profit:               X

Less: Capital allowances (capped): (X)
Less: Loss relief:                 (X)
= Total Profit (Taxable):          X

CIT at [0% / 20% / 30%]:           X
TET at 3% of assessable profit:    X
NITDA / NASENI / PTF (if app):     X
= Total federal tax liability:     X

Less: WHT credits:                 (X)
Less: Advance tax paid:            (X)
Less: Foreign tax credit:          (X)
= Net tax payable:                 X

Minimum tax check (CITA s.33):     [pass/fail]
Filing: CIT Self-Assessment, FIRS Tax Pro-Max, due 30 June 2026
Payment: Remita RRR via TSA; instalments under CITA s.77 available

---

Section 10 — Payment instructions block (for the action list)

# Payment Instructions

## Federal payments via Tax Pro-Max / Remita

1. Log into Tax Pro-Max → CIT module → File 2026 YOA return
2. After submission, Tax Pro-Max generates Assessment Notice + Remita RRR
3. Note the RRR (15-digit)
4. Pay via:
   - Bank teller (any commercial bank) — quote RRR
   - Bank internet banking — Remita Bills Payment menu
   - Bank mobile app — Remita section
   - USSD — bank-specific Remita short code
   - POS at FIRS office
5. Bank confirms → Remita issues e-Receipt (RTR)
6. Return to Tax Pro-Max; payment auto-reconciles; status changes to "Paid"
7. Save: Assessment Notice PDF, RRR slip, Remita e-Receipt, Tax Pro-Max Payment Confirmation

## State payments via State IRS portal / Remita

1. Log into State IRS portal (e.g., LIRS eTax for Lagos)
2. File Form A (PIT) or Form H1 (PAYE) as applicable
3. Portal generates Assessment + Remita RRR
4. Pay via Remita (same channels as federal)
5. Retrieve filing acknowledgement → basis for State TCC

## Statutory contributions (parallel — not via Tax Pro-Max)

- Pension: direct bank transfer to PFA custodian within 7 working days of salary payment
- NHF: FMBN portal
- ITF: ITF portal — annual return + payment by 1 April
- NSITF: NSITF portal — monthly + annual reconciliation

---

Section 11 — Filing instructions block (federal and state, with deadlines)

# Filing Instructions

## Federal (FIRS)
- CIT Self-Assessment: Tax Pro-Max, due 30 June 2026 (for 31 Dec 2025 FYE)
- TET: included in CIT return
- VAT 002 (December 2025): Tax Pro-Max, due 21 January 2026
- WHT (December 2025): Tax Pro-Max, due 21 January 2026
- Required attachments: Audited Financial Statements, Tax Computation, Capital Allowances Schedule, Compliance Certificates (ITF, NSITF, PenCom, NHF)

## State (State IRS — taxpayer's state of residence)
- Form A (Individual annual PIT): State IRS portal, due 31 March 2026
- Form H1 (Employer annual PAYE reconciliation): State IRS portal, due 31 January 2026
- Form G (Monthly PAYE): State IRS portal, due 10th of following month
- WHT (individuals): State IRS portal, due 10th of following month

## Statutory bodies (parallel filings)
- Pension contribution schedule: PFA, within 7 working days of salary payment (PenCom monitoring)
- NHF: FMBN, monthly
- ITF: ITF, annual by 1 April 2026
- NSITF: NSITF, monthly + annual reconciliation by 31 March 2026

## Post-filing
- Apply for FIRS TCC (Federal Tax Clearance Certificate) via Tax Pro-Max
- Apply for State TCC via State IRS portal
- Both TCCs are 12-month validity; renew annually

---

Section 12 — Final taxpayer action list

# Action List — [Taxpayer Name] — Tax Year 2025 / Year of Assessment 2026

## Immediate (before earliest deadline — 10 January 2026 for December PAYE)

### Individuals — deadlines:
1. **10 January 2026** — Confirm December 2025 PAYE (Form G) remitted by employer
2. **31 March 2026** — File Form A with State IRS; pay net PIT of ₦X via Remita RRR
3. Apply for State TCC after Form A acceptance

### Employers (PAYE):
1. **10 January 2026** — File December 2025 Form G; remit December PAYE
2. **31 January 2026** — File Form H1 (annual PAYE reconciliation) with State IRS
3. **31 March 2026** — NSITF annual reconciliation
4. **1 April 2026** — ITF annual contribution + return
5. Apply for compliance certificates: ITF, NSITF, PenCom, NHF (each ~12-month validity)

### Companies (CIT):
1. **21 January 2026** — File VAT 002 December; remit VAT
2. **21 January 2026** — File WHT December schedule; remit WHT
3. **31 January 2026** — File Form H1 with State IRS (employer reconciliation)
4. **31 March 2026** — NSITF annual; ensure compliance certificates current
5. **1 April 2026** — ITF annual return + payment
6. **30 June 2026** — File CIT Self-Assessment on Tax Pro-Max for FY ending 31 December 2025; remit CIT + TET via Remita
7. Apply for FIRS TCC after CIT acceptance
8. Generate transfer pricing local file (if related-party transactions); attach to CIT filing

## Monthly compliance through 2026

| Item | Authority | Due |
|---|---|---|
| PAYE Form G | State IRS | 10th of following month |
| WHT (companies) | FIRS Tax Pro-Max | 21st of following month |
| WHT (individuals) | State IRS | 10th of following month |
| VAT 002 | FIRS Tax Pro-Max | 21st of following month |
| Pension (RSA) | PFA | 7 working days from salary |
| NHF | FMBN | Monthly |
| NSITF | NSITF | Monthly (14 days) |

## Record retention

Per CITA Section 26 (companies) and PITA Section 53 (individuals), accounting records must be retained for **6 years** after the year to which they relate (i.e., FY 2025 records must be kept until end of 2031). FIRS practice for VAT records under VAT Act Section 31: **6 years**. Records may be kept in electronic form provided they are accessible to FIRS / State IRS on demand. Cross-border storage is permissible but reasonable on-demand access in Nigeria is expected.

Retain at minimum:
- Audited financial statements
- General ledger and supporting source documents
- WHT credit notes (received and issued) with serial numbers
- VAT invoices and VAT credit notes
- Remita e-Receipts (RTRs) and Tax Pro-Max payment evidence
- Tax Pro-Max filing acknowledgements
- State IRS filing acknowledgements
- Form G monthly + Form H1 annual employer returns
- Compliance certificates (ITF, NSITF, PenCom, NHF)
- TCCs (federal and state)

---

Section 13 — 2026 planning notes (NTA 2025 transitional impact)

The capstone produces a forward-looking section so the taxpayer arrives at the next year's filing aware of the structural changes the Nigeria Tax Act 2025 introduces.

13.1 NTA 2025 — what changes from 1 January 2026

Area	FY 2025 (current)	FY 2026 (NTA 2025)	Action
CIT large-company rate	30%	25%	Re-forecast tax in 2026 budget
Small company threshold	Turnover ≤ ₦25M	Turnover ≤ ₦100M	Many medium companies move into small-company exemption (0% CIT)
TET + NITDA + NASENI	3% + 1% + 0.25% separate levies	Consolidated Development Levy of 4%	Single line in 2026 computation
Minimum tax (companies)	Section 33 CITA: 0.5% turnover	MEFR 15% for MNE groups ≥ €750M consolidated revenue (Pillar Two)	Pillar Two diagnostic for MNE clients
PIT structure	Graduated 7–24%, CRA, Sixth Schedule reliefs	New brackets 0–25%; ₦800K tax-free threshold; rent relief ₦200K	Update payroll PAYE calculations from 1 Jan 2026
TIN	Separate FIRS TIN (companies) and JTB TIN (individuals)	Unified TIN — single identifier	Re-validate identifiers post 1 Jan 2026
Tax authority	FIRS	Nigeria Revenue Service (NRS)	Portal rebrand; processes substantively unchanged in short term
VAT rate	7.5%	7.5% (unchanged — proposed increase dropped)	No change
Digital services	Significant Economic Presence rules (FA 2019)	NTA 2025 codifies + expands; includes non-resident e-commerce	If MNE: review SEP exposure
Consolidated view	Separate modules in Tax Pro-Max	Nigeria Tax Account consolidates all obligations in one ledger from 1 Jan 2026	Reconciliation should be easier post-rollout

13.2 Provisional / advance tax for 2026

• CIT: Plan provisional CIT under CITA Section 77 if the company will pay in instalments; first instalment due with provisional return (typically within 3 months of FY-end). Provisional return is filed on the basis of current-year forecast.
• PIT: Self-employed individuals pay provisional PIT in 4 quarterly instalments under PITA Section 44 (15 April, 15 July, 15 October, 15 January). Compute on best estimate of FY 2026 chargeable income at NEW NTA 2025 rates.

13.3 Compliance certificate renewals

All four compliance certificates (ITF, NSITF, PenCom, NHF) renew annually. Plan applications early Q1 2026 to ensure TCC is not blocked. Each can take 2–6 weeks.

13.4 Transfer pricing (companies)

If related-party transactions exist:

• Local File: Required for entities with related-party transactions ≥ ₦300M (FIRS TP Regulations 2018 Regulation 16). Due with CIT return (30 June 2026 for 31 Dec 2025 FYE).
• Master File: Required for entities part of MNE groups ≥ ₦160B consolidated revenue. Same due date.
• CbCR Notification: Annual within 12 months of FY-end if MNE.
• TP Declaration Form: Submitted as schedule to Tax Pro-Max return.

13.5 Minimum tax monitoring

Under CITA Section 33, where a company has insufficient tax payable (e.g., due to large capital allowances or losses), minimum tax of 0.5% of gross turnover applies (excluded: small companies under Section 40, companies in first 4 years of operation, manufacturing within first 4 years, agricultural). Flag in 2026 forecast if minimum tax is likely to bite.

13.6 Excess Dividend Tax (EDT)

Under CITA Section 19, if a company pays dividends in excess of its taxable profits for the year, the excess is taxable at the corporate rate. Plan dividend distributions to avoid EDT exposure. Finance Act 2020 narrowed but did not eliminate EDT.

---

Section 14 — Conservative defaults

When inputs from upstream skills are ambiguous or missing, apply the following defaults and flag for the reviewer:

Situation	Conservative default
Cross-skill reconciliation differs by > ₦1,000	Flag as "Needs Input"; do not silently round
Tax Pro-Max billing reference / Remita RRR unknown	Use "TBC — generate via Tax Pro-Max" and DO NOT estimate the RRR
Company size classification borderline (turnover near ₦25M / ₦100M boundary)	Use HIGHER tax bracket as conservative; flag for reviewer
State of residence ambiguous (multi-state employee)	Default to state of principal employment per PITA First Schedule; flag
Capital allowances cap applicability unclear (non-manufacturing vs manufacturing)	Apply 66 2/3% cap; flag for reviewer
TIN missing or unverified	Cannot finalise return; flag as blocker
WHT credit notes claimed but not in hand	Exclude the credit; flag for taxpayer to obtain
Audit requirement unclear (small company exempted from audit by CAMA 2020 Section 402 — must be a small company per CAMA definition)	Recommend audit unless clearly exempt; conservative position
Donation deductibility uncertain (recipient not on CITA Sixth Schedule)	Disallow; flag for reviewer
December payroll true-up not booked	Treat year as incomplete; cannot finalise return until December payroll closed
Foreign tax credit certificate of payment missing	Disallow credit; flag for documentation
Related-party transactions undocumented	Flag transfer pricing risk; do not assume arm's-length
Compliance certificate missing or expired	Flag as TCC blocker
NTA 2025 rate or threshold assumed for FY 2025	Reject; FY 2025 uses pre-NTA rules; NTA 2025 applies from 1 Jan 2026 only
Tax Pro-Max payment evidence missing	Mark assessment as "pending payment"; advise to settle before deadline

Tolerance rule (repeated for emphasis): ₦1,000 reconciliation tolerance. Any larger discrepancy is escalated, not absorbed.

---

Section 15 — Refusals

R-NG-ASM-1 — Upstream skill did not run. Name the missing skill. Continue with available data; flag the gap; do not fabricate the missing computation.

R-NG-ASM-2 — Upstream self-check failed. Note the specific check; continue but flag.

R-NG-ASM-3 — Cross-skill reconciliation > ₦1,000. Raise as "Needs Input"; do not silently round.

R-NG-ASM-4 — Out of scope: Petroleum Profits Tax (PPTA), Hydrocarbon Tax under PIA 2021, mining royalties, telecommunications-specific levies, gaming tax, betting tax, freezone tax holidays (NEPZA / OGFZA pioneer status under Industrial Development Income Tax Relief Act). Flag for human specialist; do not attempt.

R-NG-ASM-5 — Out of scope: non-resident companies / non-resident individuals, Permanent Establishment determination under DTT, mixed-residency years, expatriate Significant Economic Presence under FA 2019 / NTA 2025. Refer to a specialist; this skill assumes full-year Nigerian tax residency.

R-NG-ASM-6 — Out of scope: combined federal-state tax disputes, Tax Appeal Tribunal (TAT) proceedings, FIRS audit defence, transfer pricing audit defence. Refer to a tax lawyer / CITN member with TAT practice.

R-NG-ASM-7 — Intake incomplete. Name the missing intake field (TIN, RC/BN, NIN, State of Residence, etc.). Cannot finalise the return until provided.

R-NG-ASM-8 — Asked to submit to Tax Pro-Max or State IRS portal directly. This skill produces a working paper. Submission is the taxpayer's (or their authorised filer's) action, after ICAN / CITN review and sign-off. Decline politely; provide the filing instructions instead.

R-NG-ASM-9 — NTA 2025 retroactive application. NTA 2025 effective dates govern; do not back-apply 2026 rates / thresholds to 2025 returns. Decline politely; explain transitional rules.

R-NG-ASM-10 — Out of scope: oil and gas sector (PIA 2021 Chapter 4 fiscal terms), pioneer status companies, free zone enterprises, NIPC-incentivised entities. Refer to specialist.

---

Section 16 — Self-checks

Check NG-ASM-1 — All upstream skills required for the chosen filing type have produced output, or the gap is flagged.

Check NG-ASM-2 — Revenue reconciles between bookkeeping, ng-vat, and the chosen income-tax skill (ng-cit / ng-personal-income-tax) within ₦1,000.

Check NG-ASM-3 — Tax credits sum correctly across PAYE, WHT, provisional tax, foreign tax credit; each WHT credit note backed by FIRS / State IRS serial number.

Check NG-ASM-4 — Form H1 sum equals Form G monthly totals within ₦1,000; December true-up is booked.

Check NG-ASM-5 — All four statutory deductions (Pension, NHF, NHIS, ITF/NSITF) remitted; compliance certificates current.

Check NG-ASM-6 — For companies: capital allowances within Section 31 cap (66 2/3% for non-manufacturing) unless manufacturing exemption applies; TWDV roll-forward ties.

Check NG-ASM-7 — Minimum tax check under CITA Section 33 performed; result documented.

Check NG-ASM-8 — CIT rate band (0% / 20% / 30%) correctly applied based on FY 2025 turnover (₦25M / ₦100M thresholds); company classified small/medium/large.

Check NG-ASM-9 — TET at 3% of assessable profit (NOT total profit); applied to ALL companies (no small-company exemption from TET per Finance Act 2023).

Check NG-ASM-10 — Filing deadlines explicitly stated in action list: 10 Jan (PAYE), 21 Jan (VAT/WHT), 31 Jan (H1), 31 Mar (Form A / NSITF), 1 Apr (ITF), 30 Jun (CIT).

Check NG-ASM-11 — Tax Pro-Max workflow described: file → Assessment → Remita RRR → Pay → e-Receipt → Reconciliation.

Check NG-ASM-12 — State IRS jurisdiction for PIT correctly identified per taxpayer's "place of residence" under PITA First Schedule.

Check NG-ASM-13 — Record retention period (6 years per CITA Section 26 / PITA Section 53 / VAT Act Section 31) is stated.

Check NG-ASM-14 — Reviewer brief contains legislation citations for every position taken (CITA, PITA, VAT Act, CGTA, TET Act, Finance Acts, NTA 2025 where prospective).

Check NG-ASM-15 — TCC application workflow noted in action list (FIRS TCC + State TCC).

Check NG-ASM-16 — ICAN / CITN reviewer sign-off requirement stated in executive summary and action list.

Check NG-ASM-17 — NTA 2025 transitional impacts flagged in 2026 planning section; rates/thresholds NOT back-applied to 2025.

---

Section 17 — Reviewer attestation block

The final working paper carries an attestation block the credentialed reviewer signs:

# Reviewer Attestation — Year of Assessment 2026 (FY 2025)

I, [Name], [ICAN/ANAN] member with ICAN/ANAN number [____], 
and [CITN member where applicable] number [____], 
acting for [Taxpayer name, TIN ________], 
have reviewed the working paper prepared by [preparer / OpenAccountants AI], 
verified the cross-skill reconciliations to my satisfaction, 
and confirm that:

  [ ] The audited financial statements (companies) or business accounts (sole 
       proprietors) on which this return is based are signed off
  [ ] Tax adjustments, capital allowances, and reliefs comply with CITA / PITA / 
       relevant Finance Acts
  [ ] Statutory compliance certificates (ITF, NSITF, PenCom, NHF) are in place 
       (or absence is flagged)
  [ ] WHT credit notes claimed have verifiable serial numbers
  [ ] VAT-to-income reconciliation is within ₦1,000 tolerance (or explained)
  [ ] PAYE Form H1 reconciles to monthly Form G remittances
  [ ] No NTA 2025 prospective rule has been back-applied to 2025
  [ ] Transfer pricing local file is prepared (where required) and attached
  [ ] Minimum tax check under CITA Section 33 (companies) is documented
  [ ] All payment due dates and Remita / Tax Pro-Max workflows are explained 
       to the taxpayer

Signed: ___________________  Date: ___________________
        [Reviewer name]
ICAN/ANAN no.: ___________________
CITN no. (if applicable): ___________________
Firm: ___________________  FRC no.: ___________________

No filing without this signed attestation.

---

Section 18 — Output files

The final output is three files:

1. [taxpayer_slug]_2025_ng_master.xlsx — Master workbook. Sheets: Cover, Identity, Form A (or CIT Self-Assessment), Tax Computation, Capital Allowances, Loss Relief, WHT Credit Notes Register, Statutory Deductions Register, VAT Reconciliation, Form H1 / Form G Reconciliation, Cross-Check Summary, Tax Pro-Max / Remita Payment Schedule, Compliance Certificates Tracker. Use live formulas where possible; verify no #REF! errors.

2. reviewer_brief.md — Markdown file with all Section 8 contents, plus the headline blocks from Section 9 and the attestation block from Section 17.

3. taxpayer_action_list.md — Markdown file with all Section 12 contents, plus the payment instructions block from Section 10 and filing instructions block from Section 11.

All three files are placed in /mnt/user-data/outputs/ and presented to the user at the end.

If execution runs out of context mid-build, complete the computation work first and produce whichever formatted outputs are finished, then state clearly which deliverables are partial.

---

Section 19 — Known gaps

1. PDF form filling is not automated; the reviewer or taxpayer enters values into Tax Pro-Max / State IRS portals using the working paper.
2. Tax Pro-Max XML / bulk upload templates are not generated by this skill; integrations with ERP / accounting software handle that.
3. Audited financial statements attachment is the taxpayer's responsibility; this skill only flags when audit is required (CAMA 2020 Section 402 small-company exemption).
4. Transfer pricing local file / master file content is referenced but not assembled here (separate skill needed for full TP documentation).
5. Petroleum Profits Tax / Hydrocarbon Tax under PIA 2021 is out of scope.
6. Pioneer status (NIPC) / freezone (NEPZA / OGFZA) regime computations are out of scope.
7. Country-by-Country Reporting XML is not assembled here.
8. NTA 2025 implementing regulations may evolve through 2025–2026; every prospective rule in this skill should be re-verified against the gazetted NTA 2025 commencement notice and any FIRS / NRS implementation guidance.
9. State IRS portal mechanics vary by state; this skill describes the LIRS pattern as the most-developed example. Smaller states may require paper filings; flag in intake.
10. CGT on shares: NTA 2025 changes the CGT treatment of certain share disposals from 1 Jan 2026 — not relevant for 2025 returns but flagged in planning.

Change log

• v1.0 (May 2026): Initial release. Modelled on mt-return-assembly, us-ca-return-assembly, and id-return-assembly. Adapted for Nigerian PIT Form A, CIT Self-Assessment via FIRS Tax Pro-Max, State IRS coordination, Remita / TSA payment, and NTA 2025 transitional impact. Coordinates nine upstream Nigeria skills.

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Section 20 — Sources

Source	Reference
Companies Income Tax Act (CITA), Cap C21 LFN 2004 (as amended)	CIT framework; Sections 31 (capital allowances cap), 33 (minimum tax), 40 (rates), 55 (filing deadline), 77 (instalments), 81 (WHT compliance), 85 (interest), Second Schedule (capital allowances), Sixth Schedule (donations)
Personal Income Tax Act (PITA), Cap P8 LFN 2004 (as amended)	PIT framework; Sections 41 (annual return), 44 (provisional tax), 73 (WHT compliance), 81 (PAYE), 94 (penalties), First Schedule (residence), Sixth Schedule (CRA & graduated rates)
Value Added Tax Act, Cap V1 LFN 2004 (as amended through Finance Act 2020)	VAT framework, 7.5% rate, monthly filing, reverse charge on imported services
Capital Gains Tax Act (CGTA), Cap C1 LFN 2004 (as amended)	CGT at 10%; Section 32 roll-over relief
Tertiary Education Trust Fund Act 2011 (as amended by Finance Act 2023)	TET at 3% of assessable profit; applies to all resident companies
Pension Reform Act 2014	Pension framework; 8% employee + 10% employer; Section 11(3) seven-day remittance
National Housing Fund Act 1992	2.5% NHF contribution
Industrial Training Fund Act (as amended)	1% of payroll; annual return
Employees Compensation Act 2010	NSITF 1% of payroll
National Health Insurance Authority Act 2022 (replacing NHIS Act)	NHIA scheme rates
Companies and Allied Matters Act (CAMA) 2020	Section 402 small-company audit exemption; CAC RC/BN issuance
FIRS Establishment Act 2007	FIRS powers; transitioning to NRS under NTA 2025
Federal Inland Revenue Service Transfer Pricing Regulations 2018	Local file, master file, TP declaration, related-party thresholds
Finance Act 2019	Small company exemption; WHT reforms; minimum tax narrowing
Finance Act 2020	VAT reforms; SEP rules; EDT narrowing; CRA enhancement
Finance Act 2021	Capital gains on shares; further VAT amendments
Finance Act 2023	TET rate to 3%; further refinements
Nigeria Tax Act 2025 (NTA 2025) — assented June 2025, key provisions effective 1 January 2026	New CIT rate (25% large), new small-company threshold (₦100M), Development Levy (4% consolidating TET/NITDA/NASENI), new PIT brackets and ₦800K threshold, unified TIN, NRS rebrand, MEFR 15% for MNEs (Pillar Two) — prospective only; does NOT apply to FY 2025
FIRS Tax Pro-Max	https://taxpromax.firs.gov.ng
Remita	https://www.remita.net
Lagos State Internal Revenue Service (LIRS) eTax	https://etax.lirs.net
FCT-IRS	https://fctirs.gov.ng
Institute of Chartered Accountants of Nigeria (ICAN)	https://icanig.org
Association of National Accountants of Nigeria (ANAN)	https://anan.org.ng
Chartered Institute of Taxation of Nigeria (CITN)	https://citn.org
Skill version	1.0

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OpenAccountants — open-source accounting skills for AI This is not tax advice. All outputs must be reviewed and signed off by a Chartered Accountant in Nigeria (ICAN or ANAN member, and where tax-specific opinions are required, also CITN-registered) before filing via FIRS Tax Pro-Max or the relevant State Internal Revenue Service portal.

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