Taxation constitutes the most reliable and sustainable mechanism through which modern states mobilise revenue for governance and development.[1] In Nigeria, this fiscal instrument has assumed heightened significance against the backdrop of declining global crude oil prices and the accelerating transition of traditional crude export destinations to alternative energy sources, largely driven by environmental imperatives and the urgency of addressing climate change.[2] The country’s historic dependence on oil receipts has thus exposed structural vulnerabilities, rendering the diversification of revenue through taxation an economic and constitutional necessity.[3]
Notwithstanding its relevance, the concept of tax itself resists simple definition. Nigerian tax statutes, notably, do not provide a precise definition of the term. Rather, they offer descriptive provisions. This failure of the Nigerian tax laws to provide a comprehensive definition of the term tax can be attributed to the fact that when you define, you limit and if limitation is placed on what is to be taxed, then the government may be denying itself new things to be taxed. Notwithstanding this, few definitions in the tax laws will be provided.
The Nigeria Tax Act, 2025 in section 202 defines the term to ‘mean any imposition, duty, levy, royalty or revenue accruing to government in full or in Part under this Act or any other law’. Likewise, the Nigerian Revenue Service (Establishment) Act, 2025 defines tax in section 42 to ‘include any duty, levy or other revenue accruable to the Government in full or in part under this Act, the laws listed in the Second Schedule to this Act or any other law’.
[1] Chioma Nwabachili, ‘Legitimizing the Taxation of Religious Institutions, Privately owned Educational Institutions and Non-governmental Organisations in Nigeria’ (2022) 8(2) International Journal of Law 52, 52
[2] Meshach N Umenweke, Matthew Izuchukwu Anushiem, Uchenna MaryJane Anushiem and Chinaza Michael Egwuatu, ‘An Appraisal of the Statutory Tax Obligations of Non-Profit Organisations in Nigeria’ (2024) 15(2) Nnamdi Azikiwe University Journal of International Law and Jurisprudence (NAUJILJ) 137, 137
[3] Ibid
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