National Assembly has released four tax reform Acts duly signed into law by President Bola Ahmed Tinubu for public record, verification and reference.
In a statement, obtained by Nigerian Kicker, House Spokesman Akin Rotimi says the Senate President, Godswill Akpabio and Speaker, House of Representatives, Abbas Tajudeen, directed the immediate release of the Certified True Copies of the Acts, including the endorsement and assent pages signed by the President.
Rotimi says this is to dispel public concerns and allegations regarding purported alterations and the circulation of unauthorised and misleading versions of the laws.
The four Acts released are:
The Nigeria Tax Act, 2025, The Nigeria Tax Administration Act, 2025, The National Revenue Service (Establishment) Act, 2025, The Joint Revenue Board (Establishment) Act, 2025.
Rotimi further notes that parliament would remain vigilant and proactive in defending the integrity of its work, clarifying that the only authentic and authoritative versions of the four tax Acts are those certified and released by the National Assembly.
Below is details of one of the four Acts:
JOINT REVENUE BOARD OF NIGERIA
(ESTABLISHMENT) ACT, 2025
ARRANGEMENT OF SECTIONS
SECTION :
PART I – OBJECTIVE AND APPLICATION
1. Objective of the Act
2. Application
PART II – ESTABLISHMENT OF THE JOINT REVENUE BOARD
3. Establishment of the Joint Revenue Board
4. Composition of the Board
5. Functions of the Board
6. Powers of the Board
7. Conflict of interest and corporate responsibility
8. Cessation of membership
9. Delegation of powers
PART III – MANAGEMENT AND STAFF OF THE BOARD
10. Executive Secretary of the Board
11. Staff of the Board
12. Pensions
13. Staff regulations
PART IV – FINANCIAL PROVISIONS
14. Funds of the Board
15. Expenditure of the Board
16. Estimates
17. Accounts and audit
18. Annual report
19. Power to accept gifts
20. Power to borrow
21. Tax exemptions
22. Accountability
PART V – ESTABLISHMENT OF TAX APPEAL TRIBUNAL
0 2025 No. 06
Joint Revenue Board of Nigeria
(Establishment) Act, 2025
24. Composition of the Tribunal
25. Qualification of a Tax Appeal Commissioner
26. Term of office
27. Cessation of office
28. Disclosure of interest
29. Jurisdiction of the Tribunal
30. Funding of the Tribunal
31. Remuneration and Conditions of Service of Tax Appeal Commissioners
32. Coordinating Secretary to the Tribunal and Secretaries to the Zones
33. Other staff of the Tribunal
34. Estimates of the Tribunal
35. Procedure of the Tribunal
PART VI – ESTABLISHMENT OF THE OFFICE OF THE TAX OMBUD
36. Establishment of the Office of the Tax Ombud
37. Appointment of the Tax Ombud
38. Cessation of tenure of the Tax Ombud
39. Staff of the Office of the Tax Ombud
40. Oath administration and document authentication
41. Powers and functions of the Office of the Tax Ombud
42. Conflict of interest
43. Limitations on authority
44. Funds of the Office of the Tax Ombud
45. Expenditure of the Office of the Tax Ombud
46. Estimates of the Office of the Tax Ombud
47. Accounts and audit
48. Reports
49. Procedures of the Office of the Tax Ombud
PART VII – MISCELLANEOUS PROVISIONS
50. Directive by the National Economic Council
51. Information and documents to be confidential
52. Official secrecy and confidentiality
53. Endorsement
54. Limitation of suits against the Board
55. Service of documents
56. Restriction on execution against property of the Board
57. Indemnity
58. Consequential amendment
59. Savings and transitional provisions
60. Interpretation
61. Short tittle
SCHEDULES
Joint Revenue Board of Nigeria
(Establishment) Act, 2025
JOINT REVENUE BOARD OF NIGERIA
(ESTABLISHMENT) ACT, 2025
ACT NO. 6
AN ACT TO ESTABLISH THE JOINT REVENUE BOARD, THE TAX APPEAL
TRIBUNAL AND THE OFFICE OF THE TAX OMBUD, FOR THE HARMONISATION,
COORDINATION AND SETTLEMENT OF DISPUTES ARISING FROM REVENUE
ADMINISTRATION IN NIGERIA; AND FOR RELATED MATTERS.
[ 26th June, 2025 ]
ENACTED by the National Assembly of the Federal Republic of Nigeria —
PART I — OBJECTIVES AND APPLICATION
1. The objectives of this Act are to —
(a) provide for a legal and institutional framework for the harmonisation
and coordination of revenue administration in Nigeria ;
(b) provide a mechanism for efficient dispute resolution ; and
(c) promote the rights of the taxpayers.
2. This Act shall apply throughout the Federal Republic of Nigeria.
PART II – ESTABLISHMENT OF THE JOINT REVENUE BOARD
3.—(1) There is established to be known as the Joint Revenue Board
(“the Board”).
(2) The Board —
(a) shall be a body corporate with perpetual succession and a common
seal ;
(b) may sue or be sued in its corporate name ; and
(c) may acquire, hold or dispose of its property.
(3) The Board shall have its head office in the Federal Capital Territory.
4.—(1) The Board shall consist of —
(a) the Chairman, who shall be the Executive Chairman of the Nigeria
Revenue Service ; and
(b) the Chairman of each State Internal Revenue Service and the Federal
Capital Territory Internal Revenue Service.
(2) The following persons shall be ex-officio members of the Board –
(a) a representative of the Minister of Finance not below the rank of a
Director.
(b) the Director-General of the National Identity Management
Commission or representative not below the rank of a Director ;
(c) the Chairman of the Revenue Mobilisation, Allocation and Fiscal
Commission or its representative not below the rank of a Director,
(d) the Comptroller-General of the Nigerian Immigration Service or a
representative not below the rank of Assistant Comptroller-General ;
(e) the Corps Marshall of the Federal Road Safety Corps or its
representative not below the rank of an Assistant Corps Marshall ;
(f) the Comptroller-General of the Nigeria Customs Service or its
representative not below the rank of an Assistant Comptroller-General ;
and
(g) a representative of the Nigeria Revenue Service not below the
rank of a Director.
(3) Notwithstanding the provisions of subsection (1), the Board may coopt any person, body or agency on a need basis not exceeding two persons.
(4) Members of the Board shall serve on a part-time basis.
(5) The provisions set out in the First Schedule to this Act shall have
effect with respect to the proceedings of the Board and other matters mentioned
in it.
5. The Board shall —
(a) integrate and maintain a database of Taxpayer Identification Numbers
for every taxable person in Nigeria in collaboration with the Nigeria Revenue
Service, State Internal Revenue Service, Local Government Revenue
Committee and other relevant government agencies ;
(b) resolve disputes between various tax authorities on the issue of
determination of residency ;
(c) advise government on double taxation matters within Nigeria, and in
respect of double taxation arrangements concluded or under consideration
with any other country, including other taxation matters having effect
throughout Nigeria ;
(d) resolve disputes between different tax authorities ;
(e) maintain a platform for revenue data collection, integration and
exchange of information among the various tax authorities in Nigeria ;
(f) promote harmonisation of taxes, levies, rates, charges and other
payments and ensure uniformity in revenue administration across Nigeria ;
(g) advise the Federal and State Governments on introduction of new taxes and changes to existing ones ;
(h)provide periodic impact analysis with recommendations on tax
framework and capacity building for all tiers of Government ;
(i) collaborate with relevant agencies to carry out surveys, ascertain
and publish relevant tax indices and statistics ;
(j) recommend, participate, facilitate or initiate fiscal and tax policy reform
in collaboration with relevant bodies ;
(k) receive, collate, analyse and publish periodic tax revenue collected
by all tax authorities ;
(l) receive, collate, analyse and publish tax expenditure on account of
tax waivers, exemptions or incentives granted by each government ;
(m) collaborate with tax authorities to undertake or support research or
similar measures with a view to stimulating economic development and
determine the manifestation, extent, magnitude and effects of tax fraud,
evasion or other matters that affect effective tax administration and make
recommendations to the Government on appropriate intervention and
preventive measures ;
(n) provide guidance for the accreditation of tax agents by the relevant
tax authorities in accordance with the relevant law ; and
(o) carry out any other function as may be assigned to it by an Act of the
National Assembly.
6. The Board shall —
(a) provide general policy guidelines relating to its functions ;
(b) manage and superintend the policies of the Board on matters relating
to the administration of its functions under this Act or any other law ;
(c) review and approve the strategic plans of the Board ;
(d) employ and determine the terms and conditions of employment
including disciplinary measures of the employees of the Board ;
(e) stipulate remuneration, allowances, benefits and pensions of the staff
and employees ; and
(f) do such other things which in its opinion are necessary to ensure the
efficient performance of the functions of the Board under this Act.
7. In the discharge of their responsibilities, members of the Board
shall —
(a) act in utmost good faith, with care, skill and diligence ;
b) have fiduciary obligations to the Board ;
(c) not act in any circumstance where their personal interest conflict
with the interest of the Board ;
(d) not make secret profit in the course of discharging official duties ;
(e) not accept any gift or advantage in whatever form or manner, for
anything done or likely to be done with respect to their responsibilities under
this Act ; and
(f) adhere to all the duties and obligations specified for directors under
the Companies and Allied Matters Act.
8. A person shall cease to be a member of the Board where, the
person —
(a) no longer occupies the office by virtue of which the person is a
member of the Board ;
(b) resigns from appointment as a member of the Board by notice ;
(c) dies or becomes incapable of carrying on the functions of the office
either arising from an infirmity of mind or body ;
(d) becomes bankrupt or makes a compromise with creditors ; or
(e) is convicted of a felony or of any offence involving dishonesty or
fraud.
9.—(1) Any power conferred and any duty imposed upon the Board
may be exercised or performed by the Board or by any officer authorised
generally or specifically in that behalf by the Board.
(2) An order, ruling or directive made or given by an officer authorised
by the Board shall not be treated as an order, ruling or directive of the Board,
until ratified by the Board pursuant to the powers vested on the Board under
this Act.
PART III – MANAGEMENT AND STAFF OF THE BOARD
10.—(1) There is appointed an Executive Secretary by the Board who
shall be —
(a) the chief executive and accounting officer of the Board ; and
(b) responsible for the execution of the policies formulated by the Board
and administration of the Board.
(2) The Executive Secretary shall –
(a) have requisite qualifications in taxation, accountancy, economics or lawlaw; and
b) possess at least 10 years of relevant experience in tax administration
or professional tax practice.
(3) The Executive Secretary shall hold office —
(a) for a term of four years, renewable for another term of four years
and no more ; and
(b) on such other terms and conditions as may be specified in the
letter of appointment.
(4) The Executive Secretary shall be responsible for —
(a) issuing notices of meetings of the Board ;
(b) keeping records of the proceedings of the Board ;
(c) conducting the Board’s correspondence ; and
(d) carrying out such other duties as the Board may determine.
(5) The Executive Secretary shall be paid such emoluments, allowances
and benefits as may be approved by the Board.
11.—(1) The Board shall appoint directly, or by way of transfer or
secondment such persons to be employees of the Board –
(a) for the proper and efficient performance of the functions of the
Board under this Act ; and
(b) on terms and conditions, including remuneration, allowances and
benefits determined by the Board, as specified in the letter of appointment.
(2) On grounds of public policy or for the purposes of capacity building
or comparative experience, the Board may approve a temporary stay of any
staff of the Board with agencies, organisations or other bodies, subject to
such terms and conditions as the Board may deem fit.
(3) The Board may appoint consultants or agents to transact any business
or to do any act required to be transacted or done in the execution of its
functions under this Act.
12.—(1) Employment in the Board shall be subject to the provisions of
the Pension Reform Act and employees of the Board shall be entitled to pension
and other retirement benefits as prescribed under the Pension Reform Act.
(2) Notwithstanding the provisions of subsection (1), nothing shall prevent
the Board from appointing any person to any office on terms which preclude
the grant of pension or other retirement benefits.
(3) For the purpose of the application of the Pension Reform Act, any
power exercisable by a Minister or other authority of the Government of the Federation, not being the power to make regulations, is vested in and shall be
exercisable by the Board.
13.—(1) The Board may make regulations relating generally to the
conditions of service of the staff and such regulations may provide for —
(a) the appointment, promotion, discipline, termination and
dismissal of staff of the Board ; or
(b) appeals by staff or employees against dismissal or other
disciplinary measures, and until such regulations are made, the Public
Service Rules shall be applicable, with such modifications as may be
necessary, to the staff of the Board.
(2) The staff regulations made under subsection (1) shall not have effect
until approved by the Board.
(3) The staff regulations made under subsection (1) shall be issued to its
staff in such manner as the Board may from time to time determine.
PART IV — FINANCIAL PROVISIONS
14.—(1) The Board shall establish and maintain a fund (“the Fund”)
for the performance of its functions under this Act.
(2) There shall be paid and credited to the Fund established under
subsection (1) of this section —
(a) annual membership fees or subscriptions payable by members of the
Board ;
(b) donations, gifts of land or other property, loans, grants, aid, endowments
and voluntary contributions upon such terms and conditions, as may be
specified by the person or organisation, provided that the terms and conditions
are not contrary to the functions and powers of the Board under this Act ;
(c) returns on investments of the Board ; and
(d) such other moneys or assets which may accrue to the Board from
other sources, including charges for regulatory or statutory services, the
disposal, lease or hire of, or any other dealing with, any property vested in
or acquired by the Board.
15. There shall be chargeable to the Fund —
(a) the cost of administration of the Board ;
(b) emoluments and allowances payable to the Executive Secretary and
members of the Board ;
(c) reimbursements to members of the Board or any committee set up
by the Board for such expenses as may be expressly authorised by the
Board ;
(d) remunerations and other costs of employment of the staff of the
Board ;
(e) amounts payable as pensions and other retirement benefits under
this Act or any other law ;
(f) costs of acquisition and upkeep of premises belonging to the Board
and any other capital expenditure of the Board ;
(g) investments, maintenance of utilities, staff promotion, training, research
and similar activities ;
(h) costs necessary for the day-to-day operations of the Board ;
(i) all sums of money payable by the Board by way of grants-in-aids,
gifts, testamentary dispositions and endowments, etc, ; and
(j) any other payment for anything incidental to the foregoing provisions
or in connection with or incidental to any other function of the Board under
this Act.
16. The Executive Secretary shall cause to be prepared, not later than
30th September in each year, an estimate of the income and expenditure of
the Board for the succeeding year for consideration and approval by the Board.
17. The Board shall keep proper accounts and records, and such accounts
shall, not later than six months after the end of each year, be audited by
auditors appointed by the Board from the list and in accordance with the
guidelines supplied by the Auditor-General for the Federation.
18. The Executive Secretary shall, not later than 30th September in
each year, submit to the Board a report of its activities during the preceding
year and shall include in such report the audited accounts for the period.
19. The Board may accept gifts of land, money, aids or other assets,
provided that the terms and conditions of the acceptance are consistent with
the functions of the Board under this Act.
20.The Board may, with the approval of the National Economic Council,
borrow by way of loan, overdraft or otherwise from any source, such sums as
it may require for the performance of its functions and meeting of its obligations
under this Act.
21. The Board shall be exempt from all taxes on income imposed under
any law in Nigeria, except with respect to its obligations to deduct and remit
taxes under any of the laws.
22. The Executive Secretary of the Board shall –
(a) keep proper accounting records, in a manner as may be determined
by the Board or relevant law, in respect of all –
(i) revenues and expenditures of the Board,
(ii) its assets, liabilities and other financial transactions, and
(iii) other revenues earned by the Board, including income on
investments;
(b) prepare an annual report, including financial statements, in accordance
with generally accepted accounting principles and practices ; and
(c) ensure that the available accounting resources of the Board are
adequate and used economically in the most effective and efficient manner,
and the accounting and other financial records are properly safeguarded.
PART V – ESTABLISHMENT OF TAX APPEAL TRIBUNAL
23.—(1) There is established, a Tax Appeal Tribunal (“the Tribunal”) to
exercise the jurisdiction and powers to settle any tax dispute and controversy
arising from the administration of this Act or any other tax laws made by the
National Assembly.
(2) The Minister may by notice in the Federal Government Gazette specify
the number of zones, matters and places in relation to which the Tribunal may
exercise jurisdiction.
24.—(1) The Tribunal shall consist of five members to be known as
”Tax Appeal Commissioners” to be appointed by the Minister.
(2) There shall be a Chairman for each zone who shall be a legal
practitioner qualified to practise with not less than 10 years cognate experience
in tax legislation and tax matters.
(3) The Chairman shall preside at every sitting of the Tribunal and in his
absence, the members shall appoint one of them to be the Chairman.
(4) The quorum at any sitting of the Tribunal shall be three members.
25.—(1) A person shall be qualified for appointment as a Tax Appeal
Commissioner if the person –
(a) has requisite qualification from a recognised institution, with at least
10 years cognate experience in law, accounting, business administration,
finance, economics or taxation ; or
(b) is a retired public servant, with at least 10 years experience in taxa dministration ; or
(c) is a member of the organised private sector.
(2) For the purpose of this section, “organised private sector” means
registered business association in Nigeria.
26. A Tax Appeal Commissioner shall hold office for a term of three
years and may be renewed for a further term of three years and no more.
27. A person shall cease to be a Tax Appeal Commissioner, where the
person –
(a) attains the age of 70 years ;
(b) resigns by giving three months’ notice, addressed to the Minister or
until a person duly appointed as his successor assumes his office, whichever
is earlier ;
(c) becomes incapable of carrying on the functions of the office arising
from an infirmity of mind or body ;
(d) is convicted of a felony or of any offence involving dishonesty or
fraud ;
(e) is removed from office by the Minister on grounds of public interest
or in the interest of the Tribunal ;
(f) has been found guilty of gross misconduct in relation to the duties of
the office ; or
(g) is disqualified from professional qualification by a professional body
by virtue of which the person qualified for the appointment.
28.—(1) Where the Tax Appeal Commissioner —
(a) has a direct or indirect interest in a matter which he has been
nominated to serve as a panel member ;
(b) has an interest that could reasonably conflict with the proper
performance of the functions of the Commissioner ; or
(c) is or was a client to any of the parties in professional capacity,
the Tax Appeal Commissioner shall disclose such interest and refrain from
sitting in any proceeding for the hearing of such appeal.
(2) Failure of the Commissioner to disclose the interest under subsection
(1) of this section shall be considered as misconduct and shall be dealt with in
accordance with the provisions of this Act by the Minister.
(3) A Tax Appeal Commissioner shall not, during his tenure, as Tax Appeal
Commissioner appear as counsel before the proceedings of the Tribunal at
any zone of the Tribunal.
29.—(1) The Tribunal shall have power to adjudicate on tax disputes,
and controversies arising from Nigeria Tax Act and Nigeria Tax
Administration Act or any other tax law made by the National Assembly or
the House of Assembly of a State.
(2) The Tribunal shall apply such provisions of the laws referred to in
subsection (1) as may be applicable in the determination or resolution of
any dispute or controversy before it.
30. The Tax Appeal Tribunal shall be funded through the Consolidated
Revenue Fund as shall be appropriation by the National Assembly.
31. The Tax Appeal Commissioners shall be paid salaries and
allowances to be determined by the Revenue Mobilisation Allocation and
Fiscal Commission and shall be as prescribed in their letters of appointment,
provided that neither the salaries and allowances nor the other terms and
conditions of service of a Tax Appeal Commissioner shall be varied to their
disadvantage after appointment.
32.—(1) The Minister shall appoint a Coordinating Secretary for the
Tribunal, who shall be —
(a) responsible for keeping records of the proceedings of the
Tribunal ;
(b) the head of the secretariat and responsible for the —
(i) day-to-day administration, and
(ii) direction and control of all other employees of the Tribunal.
(2) In addition to the Coordinating Secretary, the Minister shall appoint
a Secretary for each of the zones of the Tribunal, who shall be responsible
for –
(a) keeping records of the proceedings of the Tribunal at the zone ;
(b) the day-to-day administration of the Tribunal at the zone; and
(c) the direction and control of all other employees of the Tribunal at
the zone.
(3) The Secretary shall hold office —
(a) for a term of four years and may be renewed for a further term
of four years and no more ; or
(b) until the attainment of the age of 60 years, whichever is earlier.
4) The official address of the Secretary appointed for each zone shall
be published in the Federal Gazette.
(5) The Secretary shall report to the Coordinating Secretary in the exercise
of the functions in subsection (2) of this section.
33.—(1) The Minister shall appoint such other employees as deemed
necessary for the efficient performance of the functions of the Tribunal and
the remuneration of persons so employed shall be determined by the National
Salaries, Incomes and Wages Commission.
(2) Employment in the Tribunal shall be subject to the provisions of
the Pension Reform Act and accordingly, officers and employees of the tribunal
shall be entitled to pension and other retirement benefits as are prescribed
under the Pension Reform Act.
34. The Tribunal shall prepare, not later than 30th September in each
year, an estimate of its income and expenditure for the succeeding year for
the purpose of appropriation by the National Assembly.
35. The procedure and other matters mentioned in the Second Schedule
to this Act shall apply to the Tribunal.
PART VI – ESTABLISHMENT OF THE OFFICE OF THE TAX OMBUD
36.—(1) There is established a body to be known as the Office of the
Tax Ombud.
(2) The Office of the Tax Ombud —
(a) shall be a body corporate with perpetual succession and a common
seal ;
(b) may sue and be sued in its corporate name ; and
(c) may own or dispose of property whether movable or immovable.
(3) The Office of the Tax Ombud shall have its head office in the Federal
Capital Territory and at least a branch office in each of the six geo-political
zones.
37.—(1) There shall be a Tax Ombud who shall —
(a) be appointed by the President on the recommendation of the Minister ;
(b) be a citizen of Nigeria ;
(c) have relevant qualifications and at least 10 years cognate experience
in taxation, law, accounting, auditing, administration or dispute resolution ;
and
(d) hold office for a term of 4 years and may be renewed for a further
term of 4 years and no more.
(2) The Tax Ombud shall be the Chief Executive and Accounting Officer
of the Office of the Tax Ombud.
38. A person shall cease to be the Tax Ombud, where the person —
(a) resigns from the appointment by a notice addressed to the President ;
(b) becomes incapable of carrying on the functions of the office either
arising from an infirmity of mind or body ;
(c) becomes bankrupt or makes a compromise with creditors ;
(d) is convicted of a felony or of any offence involving dishonesty or
fraud ;
(e) is removed from office by the President on grounds of public interest ;
(f) has been found guilty of contravening the Code of Conduct Bureau
and Tribunal Act, or gross misconduct in relation to their duties ; or
(g) is disqualified from professional qualification by a professional body
by virtue of which the person qualified for the appointment.
39.—(1) The Office of the Tax Ombud may appoint such officers and
other staff as may be considered necessary for the efficient performance of
the functions and exercise of the powers of the Office under this Act.
(2) The staff shall be subject to such terms and conditions of service as
may be determined by the Office of the Tax Ombud with the approval of the
Minister.
(3) The staff shall perform their duties under the direction and supervision
of the Office of the Tax Ombud.
(4) Employment in the Office of the Tax Ombud shall be subject to the
provisions of the Pension Reform Act and officers and employees of the
Office of the Tax Ombud shall be entitled to pensions and other retirement
benefits as prescribed under the Pension Reform Act.
(5) Staff of the Office of the Tax Ombud shall be persons who have
relevant qualifications and experience in taxation, law, accounting, auditing,
administration or any other field related to the functions and powers of the office.
40.—(1) For the purpose of this Act, an officer of the Office of the Tax
Ombud may be authorised to administer oaths and to authenticate various
affidavits, affirmations or declarations.
(2) Authenticated documents in subsection (1) of this section shall be
accepted as evidence in legal proceedings and no further verification or proof
of the individual’s signature, seal or official capacity is required in this regard.
41.—(1) The Office of the Tax Ombud shall have the powers necessary
or expedient for the performance of its functions under this Act, including
power to —
(a) serve as an independent and impartial arbiter to review and resolve
complaints relating to tax, levy, regulatory fee and charges, customs duty or
excise matters ;
(b) review complaint against tax officials and authorities and resolve it
through mediation or conciliation by adopting informal, fair and cost-effective
procedures ;
(c) receive and investigate complaints lodged by taxpayers regarding the
actions or decisions of the tax authorities, agencies or their officials ;
(d) enter and inspect any premises or place where any tax authority,
agency or official performs any function or duty under any law imposing
taxes, levies, charges and fees for the purpose of carrying out
investigation ;
(e) invite and examine any person who may have information or evidence
relating to a complaint or an investigation ;
(f) make recommendations of its findings to the revenue authorities and
other government agencies on matters relating to taxes, levies, charges and
fees, for implementation ;
(g) institute legal proceedings on behalf of the taxpayer ;
(h) provide information and raise awareness of taxpayer rights and
obligations, functions of the tax authorities and the role of the office of the
Tax Ombud ;
(i) identify and review systemic and emerging issues on fiscal policies
and its impact on the tax system, in collaboration with the relevant
agencies ;
(j) serve as a watch-dog against any arbitrary fiscal policy of the
Government or by any of its agency and report such policy to the National
Assembly ;
(k) issue guidelines, directives or orders for the resolution of complaints
or the implementation of recommendations ; and
(l) delegate any of the powers or functions to any officer of the Tax
Ombud.
(2) ) In the exercise of its functions under this Act, the Office of the Tax
Ombud shall not charge a fee.
42. An officer of the Office of the Tax Ombud, in the exercise the
functions under section 41 of this Act, shall —
(a) act in utmost good faith, with care, skill and diligence ;
(b) maintain independence and impartiality at all times ;
(c) not act in any circumstance where personal interests conflict with
the functions of the Office of the Tax Ombud ;
(d) disclose any conflict of interest in relation to any complaint or
investigation and an officer so conflicted shall refrain themselves from
dealing with such complaint or investigation ;
(e) not make secret profit in the course of discharging official duties ;
(f) not accept any gift or advantage in whatever form or manner, for
anything done or likely to be done with respect to their responsibilities
under this Act ; and
(g) publish studies, research, findings, recommendations, insights, or
proposals concerning any matter under consideration by the Office of the
Tax Ombud.
43. The Office of the Tax Ombud shall not have jurisdiction to —
(a) interpret tax legislations other than to the extent that it relates to
operational, procedural or administrative issues arising from the application
of the provisions of the relevant tax law ;
(b) review or determine issues that are subjudice before a court of
competent jurisdiction or tribunal on the date of the receipt of a
complaint ;
(c) determine any tax liability or duty or issue tax assessment ; or
(d) review any complaint by or on behalf of a tax official concerning
matters relating to the relevant tax authority in respect of any personal
grievance relating to the office.
44.—(1) The Office of the Tax Ombud shall be funded from the
Consolidated Revenue Fund, as may be appropriated by the National Assembly.
(2) There shall be paid and credited to the fund established under
subsection (1) —
(a) take-off grants from the Federal Government ;
(b) money as may be appropriated by the National Assembly ;
(c) gifts of land, money or other property on such terms and conditions
as may be specified by the person or organisation making the gift provided
that the terms and conditions are not contrary to the objectives and functions
of the Office of the Tax Ombud under this Act ; and
(d) all other money which may accrue to the Office of the Tax Ombud
including the disposal, lease or hire of, or any other dealing with, any
property vested in or acquired by the Office of the Tax Ombud.
45. There shall be chargeable to the fund —
(a) the cost of administration of the Board ;
(b) emoluments and allowances payable to the Executive Secretary and
members of the Board ;
(c) reimbursements to members of the Board or any committee set up
by the Board for such expenses as may be expressly authorised by the
Board ;
(d) remunerations and other costs of employment of the staff of the
Board ;
(e) amounts payable as pensions and other retirement benefits under
this Act or any other law ;
(f) costs of acquisition and upkeep of premises belonging to the Board
and any other capital expenditure of the Board ;
(g) maintenance of utilities, staff promotion, training, research and similar
activities ;
(h) costs necessary for the day-to-day operations of the Board ;
(i) all sums of money payable by the Board by way of grants-in-aids,
gifts, testamentary dispositions, endowments, etc.; and
(j) any other payment for anything incidental to the foregoing provisions
or in connection with or incidental to any other function of the Board
under this Act.
46. The Tax Ombud shall cause to be prepared, not later than 30th
September in each year, an estimate of income and expenditure for the
succeeding year for the purpose of appropriation by the National Assembly.
subsection (1) —
(a) take-off grants from the Federal Government ;
(b) money as may be appropriated by the National Assembly ;
(c) gifts of land, money or other property on such terms and conditions
as may be specified by the person or organisation making the gift provided
that the terms and conditions are not contrary to the objectives and functions
of the Office of the Tax Ombud under this Act ; and
(d) all other money which may accrue to the Office of the Tax Ombud
including the disposal, lease or hire of, or any other dealing with, any
property vested in or acquired by the Office of the Tax Ombud.
45. There shall be chargeable to the fund —
(a) the cost of administration of the Board ;
(b) emoluments and allowances payable to the Executive Secretary and
members of the Board ;
(c) reimbursements to members of the Board or any committee set up
by the Board for such expenses as may be expressly authorised by the
Board ;
(d) remunerations and other costs of employment of the staff of the
Board ;
(e) amounts payable as pensions and other retirement benefits under
this Act or any other law ;
(f) costs of acquisition and upkeep of premises belonging to the Board
and any other capital expenditure of the Board ;
(g) maintenance of utilities, staff promotion, training, research and similar
activities ;
(h) costs necessary for the day-to-day operations of the Board ;
(i) all sums of money payable by the Board by way of grants-in-aids,
gifts, testamentary dispositions, endowments, etc.; and
(j) any other payment for anything incidental to the foregoing provisions
or in connection with or incidental to any other function of the Board
under this Act.
46. The Tax Ombud shall cause to be prepared, not later than 30th
September in each year, an estimate of income and expenditure for the
succeeding year for the purpose of appropriation by the National Assembly.
47. The Tax Ombud shall keep proper accounts and records, and such
accounts shall, not later than six months after the end of each year, be audited
by auditors appointed from the list and in accordance with the guidelines supplied
by the Auditor-General for the Federation.
48.—(1) The Tax Ombud shall, not later than 30th September in each
year, submit to the Minister, a report of activities during the immediately
preceding year, and shall include in such report the audited accounts of the
Office of the Tax Ombud.
(2) The Minister shall within 30 days of receipt of the report present a
copy to the President and the National Assembly.
(3) The Tax Ombud shall publish a quarterly report within 30 days of the
end of each quarter containing relevant details, including a summary of identified
systemic and emerging issues.
49. The procedure and other matters mentioned in the Third Schedule to
this Act shall apply to the Office of the Tax Ombud.
PART VII – MISCELLANEOUS PROVISIONS
50. Subject to the provisions of this Act, the National Economic Council
(NEC) may give to the Board such directives of fiscal policy or revenue
matters, with regards to the exercise of its functions as may be considered
necessary and the Board shall comply with the directives.
51.—(1) Without prejudice to the provisions of any other law concerning
data privacy, data protection, and unlawful disclosure of institutional information
or communication, all internal memorandum and communication of the Board
shall be confidential.
(2) Except as otherwise provided under this Act, any other law or any
enabling agreement or arrangement or as otherwise authorised by the Board
or the Executive Secretary, any person who discloses institutional information,
communication, document or internal memorandum of the Board, commits an
offence under this Act and is liable on conviction, to a fine of N1,000,000.00
or to imprisonment for a term not exceeding three years or both.
52.—(1) A person in an official duty or being employed in the
administration of this Act shall regard and deal with all documents and
information as secret and confidential.
(2) A person in possession of or in control of, originals or copies of any
document or information, who at any time communicates or attempts to
communicate such information or anything contained in such document, other
than a person to whom he is authorised by the Board to communicate it,
commits an offence under this Act and is liable on conviction, to fine of
N500,000.00 or to imprisonment for a term not exceeding three years or both.
53. Anything done or required to be done by the Board pursuant of any
of its powers or functions under this Act may be endorsed under the hand of
the Chairman, Executive Secretary or of an officer who has been duly authorised
by the Board for the purpose under this section.
54.—(1) Subject to the provisions of this Act, the provisions of the Public
Officers Protection Act shall apply in relation to any suit instituted against any
member of the Board, the Executive Secretary, officer or employee of the
Board or the Board itself.
(2) Notwithstanding anything contained in any other law, no suit shall lie
or be instituted in any court against the Board, Executive Secretary, a member
of the Board, or employee of the Board for any act done in pursuance to or
execution of this Act or in respect of any alleged neglect or default, unless it is
commenced —
(a) within six months after the act, neglect or default complained of; or
(b) in the case of a continuation of damage or injury, within six months
after the ceasing of such damage or injury.
(3) No suit shall be commenced against the Board, Executive Secretary,
a member of the Board, or employee of the Board until the expiration of one
month after a written notice of intention to commence the suit has been served
on it by the intended plaintiff or his agent.
(4) The notice referred to in subsection (3) shall clearly state the —
(a) cause of action ;
(b) particulars of claim ;
(c) name and place of abode of the intending plaintiff ; and
(d) relief to be claimed.
55. A notice, summons or other document required or authorised to be
served on the Board under the provisions of this Act or any other law may be
served by delivering it to the Executive Secretary, through registered post or
courier; addressed to the Executive Secretary at the head office of the Board,
or forwarded to his approved or authorised e-mail address.
56.—(1) In any action or suit against the Board, no execution or
attachment of process shall be issued against the Board unless three months’
notice of the intention to execute or attach has been given to the Board.
(2) Any sum of money which by the judgement of any court has been
awarded against the Board shall, subject to any direction given by the court,
where no notice of appeal against the judgement has been given, be paid from
the fund of the Board.
57. The Executive Secretary, any member of the Board, officer or
employee of the Board shall be indemnified out of the assets of the Board
against any liability incurred in defending any legal proceeding brought against
them in their capacity as Executive Secretary, member of the Board, or an
employee of the Board.
58.—(1) The Personal Income Tax Act Cap. P8 L.F.N. 2004, is amended
by deleting section 86 (“the deleted section”).
(2) Without prejudice to section 6 of the Interpretation Act, the amendment
of the Act referred to in subsection (1) of this section shall not affect anything
done or purported to have been done under the deleted section.
59. Notwithstanding the provisions of section 58 of this Act —
(a) anything done or purported to have been done by the Joint Tax Board,
shall continue to subsist as if done under this Act, and any action or purported
action shall be deemed to have been taken by the Board established under
this Act ;
(b) all assets, funds, resources and other immovable property which
before the commencement of this Act were vested in the Joint Tax Board
shall be vested in the Board established under this Act ;
(c) all rights, interest, obligations and liabilities of the Joint Tax Board
existing before the commencement of this Act under any contract or
instrument, or in law or in equity, shall by virtue of this Act be assigned to
and vested in the Board established under this Act ;
(d) all persons shall as from the commencement of this Act have the
same rights, powers and remedies against the Board established under this
Act as they had against the Joint Tax Board before the commencement of the Act.
) any regulation, order, rules or notice made or issued or deemed to be
made or issued by, or for the purpose of, the Joint Tax Board existing
before the commencement of this Act shall be deemed to have been
made or issued by or for the purpose of the Board and shall continue in
force until revoked or amended, subject to such modifications as may be
applicable to the Board established under this Act ;
(f) any proceedings commenced or pending immediately prior to the
commencement of this Act shall be continued and disposed of under the
deleted section ;
(g) a reference to the Joint Tax Board, or any person under their control
or a document issued in the name of the Joint Tax Board, to be read,
unless the context otherwise requires, as a reference to the Board or any
person under the control of the Board established under this Act ;
(h) the Secretary to the Board appointed before the commencement of
this Act shall continue to hold office for the unexpired duration of his term
as Executive Secretary as if he has been appointed under this Act ;
(i) the staff of the Board before the commencement of this Act shall
continue to hold office and under the same terms and conditions.
60. In this Act —
“Board” means the Joint Revenue Board of Nigeria established under
section 3 of this Act ;
“Chairman” means the Chairman of the Board appointed under section
4 (1) (a) of this Act ;
“consultants” includes tax practitioners, accountants, legal practitioners
or any other recognised professionals that have been certified by relevant
professional bodies in Nigeria ;
“document” includes any record of information supporting accounts and
accounting records, including reports or correspondences or memoranda
or minutes of meeting, however compiled, recorded or stored, whether in
written or printed form or micro-film, digital, magnetic, electronic or optical
form or otherwise and all types of information stored in computer and any
other similar equipment ;
“Executive Secretary” means the Executive Secretary of the Board
appointed under Section 10 of this Act ;
“Government” the Federal Government, State Government or the Federal
Capital Territory, and Local Government Council ;
“gross misconduct” ” has the meaning ascribed to it in the Public Service
Rules of the Federation ;
“Minister” means the Minister charged with responsibility for matters
relating to finance and “Ministry” shall be construed accordingly ;
“Nigeria” for the purpose of this Act, means the Federal Republic of
Nigeria, and when used in a geographical sense, it includes the territorial
waters of the Federal Republic of Nigeria, and any area outside the territorial
waters, including the continental shelf, which in accordance with international
law has been or may hereafter be designated, under the law of the Federal
Republic of Nigeria, as an area within which the right of the Federal Republic
of Nigeria with respect to the seabed, its subsoil, its superjacent waters and
their natural resources may be exercised now and in the future ;
“organised private sector” means registered business association in
Nigeria ;
“person” includes an individual, a body of individuals, a company or
body of companies, any incorporated or unincorporated body of persons ;
“President” means the President of the Federal Republic of Nigeria.
61. This Act may be cited as the Joint Revenue Board of Nigeria Establishment) Act, 2025.
SUPPLEMENTARY PROVISIONS RELATING TO THE PROCEEDINGS OF THE BOARD
Proceedings of the Board
1. Subject to this Act and Section 27 of the Interpretation Act, the Board
shall have power to regulate its proceedings and may make standing orders
with respect to the holding of its meetings, and those of its committees, notices
to be given, the keeping of minutes of its proceedings, the custody and production for inspection of such minutes and such other matters as the Board may,
from time to time, determine.
2. There shall be at least three ordinary meetings of the Board in every
calendar year and subject thereto, the Board shall meet whenever it is convened by the Chairman, and if the Chairman is requested to do so by notice
given by not less than four other members, a meeting of the Board shall be
convened within 14 days from the date on which the notice was given.
3. Every meeting of the Board shall be presided over by the Chairman
and if the Chairman is unable to attend a particular meeting, the members
present at the meeting shall elect one of them to preside over the meeting.
4. The quorum of any meeting of the Board shall be one – third of members including the Chairman of the Board.
5. The Board shall meet for the conduct of its business at such places in
Nigeria and on such days as the Chairman may appoint.
6. A question put before the Board at a meeting shall be decided by
consensus and where this is not possible, by a majority of the votes of the
members present and voting.
7. The Chairman of the Board shall, in the case of an equality of votes,
have a casting vote in addition to a deliberative vote.
8. Where the Board seeks the advice of any person on a particular matter, the Board may invite that person to attend for such period as it deems fit,
but a person who is invited by virtue of this paragraph shall not be entitled to
vote at any meeting of the Board and shall not count towards the quorum.
Committees
9. The Board may appoint one or more committees to carry out on behalf of the Board any of its functions as the Board may determine and report
on any matter with which the Board is concerned.
10. A committee appointed under paragraph 9 of this Schedule shall be
presided over by a member of the Board and shall consist of such number of
persons, not necessarily all members of the Board, as may be determined by
the Board, and a person other than a member of the Board shall hold office on
the committee in accordance with the terms of appointment.
11. A decision of a committee of the Board shall be of no effect until it
is confirmed by the Board.
Conflict of Interest
12. Any member of the Board or committee who has a personal interest
in any contract or arrangement entered into or proposed to be considered by
the Board or any committee shall —
(a) disclose their interest to the Board or committee ; and
(b) not vote on any question relating to the contract or arrangement.
Miscellaneous
13. The fixing of the seal of the Board shall be authenticated by the
signature of the Executive Secretary and/or the Chairman of the Board or
such other person authorised by the Board to act for that purpose.
14. A contract or an instrument which, if made or executed by any
person not being a body corporate, shall not be required to be under seal, may
be made or executed on behalf of the Board by the Executive Secretary or by
any person generally or specifically authorised to act for that purpose by the
Board.
15. A document purporting to be a contract, an instrument or other
document signed or sealed on behalf of the Board shall be received in evidence and, unless the contrary is proved, be presumed without further proof,
to have been properly signed or sealed.
16. The validity of any proceeding of the Board or its committees shall
not be affected by –
(a) any vacancy in the membership of the Board or its committees ;
(b) reason that a person not entitled to do so took part in the proceedings ;
or
(c) any defect in the appointment of a member.
Second Schedule
Section 35
PROCEDURE OF THE TAX APPEAL TRIBUNAL
Criminal Prosecutions
1. Where in the course of its adjudication, the Tribunal discovers evidence of possible criminality, the Tribunal shall be obliged to pass such information to the appropriate criminal prosecuting authorities, including, the relevant tax authority, the Office of the Attorney General of the Federation or the
Attorney-General of any state of the Federation or any relevant law enforcement agency for appropriate action.
Appeals from decisions of the relevant tax authority
2.—(1) A taxable person aggrieved by an assessment, demand notice,
action, decision of the tax authority, or a dispute as to residency under the
provisions of the tax laws, may appeal against such decision or assessment
within the period stipulated under this Act to the Tribunal.
(2) An appeal under this Part shall be filed within a period of 30 days
from the date on which a copy of the assessment, demand notice, action or
decision which is being appealed against is made, or deemed to have been
made by the relevant tax authority and it shall be in such form and be accompanied by such fee as may be prescribed.
(3) Notwithstanding the provisions of subparagraph (2) of this paragraph,
the Tribunal may entertain an appeal after the expiry of the said period of 30
days if it is satisfied that there was sufficient cause for the delay.
(4) Where a notice of appeal is not given by the appellant as required
under this paragraph within the period specified, the assessment or demand
notices shall become final and conclusive and the relevant tax authority may
charge interests and penalties in addition to recovering the outstanding tax
liabilities which remain unpaid from any person through proceedings at the
Tribunal.
Appeal by Relevant Tax Authorities
3. A relevant tax authority aggrieved by the non-compliance by a taxable person in respect of any provision of the tax laws or in respect of any
assessment, demand notice, action or decision may appeal to the Tribunal in
the Zone where the taxable person is resident giving notice in writing through
the Secretary to the Tribunal
Liquidated Money Claim Affidavit
4. Where an Appeal is made to the Tribunal in respect of a claim to
recover a debt or liquidated money demand and the Appeal is supported by an
affidavit setting forth the grounds upon which the claim is based and stating
that in the deponent’s belief there is no defence, the Tribunal shall, if satisfied
that there are good grounds for believing that there is no defence, enter the
Appeal for hearing in what shall be called the “Liquidated Money Claim
Appeal”.
Appeal by Summons
5. Where the issue before the Tribunal is on interpretation of taxing
provisions, other tax laws, rules or regulation without dispute of fact, the Tribunal shall hear and determine the Appeal by affidavit evidence.
Settlement out of Tribunal
6.—(1) Where an Appeal is before the Tribunal for the first time, the
Chairman may grant to the parties time, not exceeding 30 days, within which
parties may explore possibilities for settlement of the dispute under the provision of the Nigeria Tax Administration Act.
(2) Where the parties fail to settle within 30 days or such other period as
the Tribunal may grant, the case shall proceed to trial.
Procedure before Tax Appeal Tribunal
7. —(1) As often as may be necessary, Tax Appeal Commissioners shall
meet to hear appeals in the jurisdiction or zone assigned to that Tribunal.
(2) The Secretary to the Tribunal shall give seven clear days’ notice to
the parties of the date and place fixed for the hearing of each appeal, except in
respect of any adjourned hearing for which the Tax Appeal Commissioners
have fixed a date at their previous hearing.
(3) Notices, documents, other than decisions of the Tribunal, may be
signified under the hand of the Secretary.
(4) Appeals before the Tax Appeal Commissioners shall be held in
public.
(5) The onus of proving that the assessment complained of is excessive
or due for payment, as the case may be, shall be on the appellant. At the
hearing of an appeal, where the representative of the relevant tax authority
proves to the satisfaction of the Tribunal appeal that —
(a) the appellant has for the year of assessment concerned, failed to pre-
pare and deliver to the tax authority returns required to be furnished under
the relevant provisions of the Nigeria Tax Act and Nigeria Tax Administration Act ;
(b) the appeal is frivolous or vexatious or constitutes an abuse of the
appeal process ; or
(c) it is expedient to require the appellant to pay an amount as security
for prosecuting the appeal, the provisions of subparagraphs (7) and (8) shall
apply.
(6) The Tribunal may adjourn the hearing of the appeal to any subsequent day and order the appellant to deposit with the tax authority, before the
day of the adjourned hearing, an amount on account of the tax charged by the
assessment under appeal equal to, the lesser of —
(a) the tax charged upon the appellant for the preceding year of assessment ; and
(b) one half of the tax charged by the assessment under appeal.
(7) Where the appellant fails to comply with the order, the assessment
against which he has appealed shall be confirmed and the appellant shall have
no further right of appeal in the tribunal with respect to that assessment.
(8) The Tribunal may, after giving the parties an opportunity of being
heard, confirm, reduce, increase or annul the assessment or make any such
order as it deems fit.
(9) Every decision of the Tribunal shall be recorded in writing by the
Chairman and a certified copy of such decision shall be supplied to the appellant or the tax authority by the Secretary, upon a request made within 7 days of
the decision.
(10) Where on the hearing of an appeal —
(a) no accounts, books or records relating to profits were produced by
or on behalf of the appellant ;
(b) such accounts, books or records were produced but rejected by the
Tribunal on the ground that it had been shown to its satisfaction that they
were incomplete or unsatisfactory ;
(c) the appellant or a representative, at the hearing of the appeal, has
neglected or refused to comply with a notice from the Secretary to the
Tribunal, without showing any reasonable cause ; or
(d) the appellant or any person employed, whether confidentially or
otherwise, by the appellant or an agent (other than a legal practitioner or
accountant acting for them in connection with their liability to tax) has
refused to answer any question put to them by the Tribunal, without showing any reasonable cause, the Chairman of the Tribunal shall record particulars of the same in his written decision.
Application of the Evidence Act
8. The proceedings of the Tribunal and its decisions shall be in compliance with the provisions of the Evidence Act.
Procedure following decision of the Tribunal
9.—(1) Notice of the amount of the tax chargeable under the assessment as determined by the Tribunal shall be served by the relevant tax authority upon the taxpayer or upon the person in whose name the taxpayer is
chargeable.
(2) An award or judgement of the Tribunal shall be enforced as if it were
a judgement of the Federal High Court upon registration of a copy of such
award or judgement with the Chief Registrar of the Federal High Court by
the party seeking to enforce the award or judgement.
Appeal to the Federal High Court
10.—(1) Any person dissatisfied with a decision of the Tribunal constituted under this Act may appeal against such decision on a point of law to the
Federal High Court upon giving notice in writing to the Secretary to the Tribunal within 30 days after the date on which such decision was given.
(2) A notice of appeal filed pursuant to subparagraph (1) of this paragraph shall set out the grounds of law on which the appellant’s case is based.
(3) Where the relevant tax authority is dissatisfied with the decision of
the Tribunal, it may appeal against such decision to the High Court on points of
law by giving notice in writing as specified in subparagraph (1) of this paragraph to the Secretary within 30 days after the date on which such decision
was given.
(4) On receipt of a notice of appeal under subparagraphs (1) or (3) of
this paragraph, the Secretary to the Tribunal shall cause the notice to be given
to the Chief Registrar of the High Court along with all the exhibits tendered at
the hearing before the Tribunal.
(5) The Chief Judge of the High Court may make rules providing for the
procedure in respect of appeals made under this Act and until such rules are
made, the High Court rules relating to hearing of appeals shall apply to the
hearing of an appeal under this Act.
Right to Presentation
11.—(1) A complainant or appellant, may either appear in person or
authorise one or more legal practitioners, a professional with the requisite knowledge and experience in tax matters or any of its officers to represent him or its
case before the Tribunal.
(2) Where the representative in any matter before the Tribunal is unable
for good cause to attend hearing, the Tribunal may adjourn the hearing for
such reasonable time as it deems fit, or admit the appeal to be made by some
other person or by way of a written address.
Application of Status of Limitation
12. The provisions of any statute of limitation and pre-action notice under this Act or the provision of the Public Officer Protection Act, shall not
apply to any appeal brought before the Tribunal.
Powers and Procedures of the Tribunal
13.—(1) The Tribunal may make rules regulating its procedures.
(2) The Tribunal shall, for the purpose of discharging its functions under
this Act, have power to –
(a) summon and enforce the attendance of any person and examine him
on oath ;
(b) require the discovery and production of documents ;
(c) receive evidence on affidavits ;
(d) call for the examination of witnesses or documents ;
(e) review its decisions ;
(f) dismiss an application for default or deciding matters exparte ;
(g) set aside any order or dismissal of any application for default or any
order made by it, exparte ; and
(h) do anything which in the opinion of the Tribunal is incidental to its
functions under this Act.
Oaths
14. Each party to an appeal shall bear its own cost.
Further Appeal
15. An appeal against the decision of the Federal High Court at the
instance of either party shall lie to the Court of Appeal.
Savings and Transitional Provisions
16.—(1) The provision of section 59 and the Fifth Schedule of the Federal Inland Revenue Service (Establishment) Act, 2007, is repealed.
(2) The Tribunal established under this Act, shall continue to hear and
conclude any proceeding commenced before the coming into effect of this
Act, as if they were commenced under this Act.
(3) The Chairman and the other members of the Tribunal appointed before the commencement of this Act shall continue to hold office for the unexpired duration of their term as if they have been appointed under this Act.
(4) The Secretary and other staff serving the Tribunal before commencement of this Act shall continue to hold office and under the same terms and
conditions.
(5) The administration and control of all rights, obligations and liabilities
of the Tax Appeal Tribunal repealed under subsection (1) are transferred to
the Tribunal established under this Act
6) The administration of any real property that were immediately before
the coming into force of this Act under the responsibility of the Tax Appeal
Tribunal are transferred to the Tribunal established under this Act.
Third Schedule
Section 49
PROCEDURE OF THE OFFICE OF THE TAX OMBUD
Complaints
1. (1) A person may lodge a complaint with the Office of the Tax Ombud,
in writing or through any other means or platform, as may be provided by the
Office of the Tax Ombud.
(2) A complainant shall only lodge a complaint with the Office of the Tax
Ombud, if the issue is unresolved by the relevant agencies.
(3) The Tax Ombud shall review and assess the complaint to determine
whether it falls within its jurisdiction and mandate.
(4) The Office of the Tax Ombud shall not entertain anonymous complaints.
(5) Where the Office of the Tax Ombud finds a complaint to be false or
misleading in any material respect, it may strike out or disregard such complaint.
(6) Where a complaint relates to malicious misrepresentation of facts of
a criminal nature, the matter shall be referred to the relevant law enforcement
agency for further investigation and possible prosecution.
Investigation
2. (1) The Office of the Tax Ombud shall initiate an investigation by –
(a) engaging the complainant, the officer or the relevant revenue or government agency to acquire additional information and evidence ; and
(b) conducting site visits, interviews or inspections.
(2) An investigation under this section shall be conducted within 14 days
of receipt of the complaint, provided that the Office of the Tax Ombud may,
where necessary, extend the period of an investigation by seven days.
(3) The conduct of an investigation shall not affect any action taken or to the Tribunal established under this Act.
) The administration of any real property that were immediately before
the coming into force of this Act under the responsibility of the Tax Appeal
Tribunal are transferred to the Tribunal established under this Act.
Third Schedule
Section 49
PROCEDURE OF THE OFFICE OF THE TAX OMBUD
Complaints
1. (1) A person may lodge a complaint with the Office of the Tax Ombud,
in writing or through any other means or platform, as may be provided by the
Office of the Tax Ombud.
(2) A complainant shall only lodge a complaint with the Office of the Tax
Ombud, if the issue is unresolved by the relevant agencies.
(3) The Tax Ombud shall review and assess the complaint to determine
whether it falls within its jurisdiction and mandate.
(4) The Office of the Tax Ombud shall not entertain anonymous complaints.
(5) Where the Office of the Tax Ombud finds a complaint to be false or
misleading in any material respect, it may strike out or disregard such complaint.
(6) Where a complaint relates to malicious misrepresentation of facts of
a criminal nature, the matter shall be referred to the relevant law enforcement
agency for further investigation and possible prosecution.
Investigation
2. (1) The Office of the Tax Ombud shall initiate an investigation by –
(a) engaging the complainant, the officer or the relevant revenue or government agency to acquire additional information and evidence ; and
(b) conducting site visits, interviews or inspections.
(2) An investigation under this section shall be conducted within 14 days
of receipt of the complaint, provided that the Office of the Tax Ombud may,
where necessary, extend the period of an investigation by seven days.
(3) The conduct of an investigation shall not affect any action taken or to be taken by the relevant revenue or government agency.
(4) Where the Office of the Tax Ombud decides not to conduct an investigation, a statement of the reasons for not conducting the investigation shall be
communicated to the complainant within seven days of receipt of the complaint.
Resolution and Recommendations
3. (1) The Office of the Tax Ombud may resolve a complaint by making
recommendations to the relevant revenue or government agency or the complainant.
(2) Where the Office of the Tax Ombud is of the opinion that the complaint amounts to abuse of office or breach of procedure, it shall communicate
its recommendations to the relevant tax authority or the persons concerned
within a period of 14 days after determination of the complaint.
(3) Where the Office of the Tax Ombud has reason to believe that a
relevant revenue or government agency has acted beyond the scope of authority or in a manner warranting criminal proceedings against such an officer,
the matter shall be referred to the relevant revenue or government agency
authority for necessary action, provided that where the relevant tax authority
fails to take appropriate action in respect of the allegations within 30 days, the
Office of the Tax Ombud shall refer the matter to the relevant law enforcement agency for necessary action.
Non-Compliance with Recommendations
4. (1) The relevant revenue or government agency shall report to the
Office of the Tax Ombud within 21 days of receiving its recommendations
stating reasons for non-compliance with the recommendations of the Office of
the Tax Ombud.
(2) Where a relevant revenue or government agency fails to implement a
recommendation, without providing satisfactory reasons for non-compliance,
the Office of the Tax Ombud shall refer the matter to the National Assembly
or the State House of Assembly to perform its oversight functions over such
recommendation.
Dispute Resolution Process
5. (1) The Office of the Tax Ombud may encourage parties to explore
alternative dispute resolution mechanisms with respect to the complaint lodged
before it.
(2) The representative of the relevant revenue or government agency, its
officers or the complainant shall
a) appear before the Tax Ombud when requested to do so ;
(b) not take any step which will impede or will be capable of
obstructing the Office of the Tax Ombud in the performance of its functions ; or
(c) not take any action which tends to prejudice or undermine a matter before the Office of the Tax Ombud.
(3) Where a party to the issue fails to comply with the provisions of
subparagraph (2), the complaint shall be deemed to be resolved against
such party.
I certify, in accordance with section 2 (1) of the Acts authentication Act,
Cap. A2, Laws of Federal of Nigeria 2004, that this is a true copy of the
Bill passed by both Houses of the National Assembly.
(Sgd)
KAMORU OGUNLANA ESQ.
Clerk to the National Assembly
11th Day of June, 2025
EXPLANATORY MEMORANDUM
This Act establishes the Joint Revenue Board, the Tax Appeal Tribunal and
the Office of the Tax Ombuds, for the harmonisation, coordination and
settlement of disputes arising from revenue administration in Nigeria.
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