The Chairman of the Presidential Fiscal Coverage and Tax Reforms Committee, Taiwo Oyedele, has clarified the coverage intent behind Nigeria’s newly gazetted tax legal guidelines, following considerations raised by KPMG Nigeria, insisting that the majority points highlighted by the agency have been misunderstandings of coverage aims or disagreements with deliberate reform decisions.
In an announcement issued on Saturday, Oyedele mentioned whereas some factors raised by KPMG have been helpful, the majority of the report mischaracterised the aims and construction of the brand new tax framework.
“We welcome all views that contribute to a shared understanding and profitable implementation of the brand new tax legal guidelines,” the assertion mentioned, noting that “just a few factors raised by KPMG are helpful, notably the place they relate to implementation dangers and clerical or cross-referencing points.”
Nevertheless, the committee emphasised that “nearly all of the publication mirrored a misunderstanding of the coverage intent, a mischaracterisation of deliberate coverage decisions, and, in a number of situations, repetitions and presentation of opinion and preferences as info.”
It famous that a number of points described as “errors,” “gaps,” or “omissions” by KPMG have been both incorrect conclusions, issues taken out of context, or areas the place the agency most well-liked totally different outcomes than these intentionally adopted.
“Whereas it’s respectable to disagree with coverage course, disagreements shouldn’t be framed as errors or gaps,” the assertion mentioned.
The Chairman offered detailed clarifications on key provisions flagged by KPMG.
On taxation of shares and the inventory market, it mentioned the framework is “structured from 0% to a most of 30%, which is about to cut back to 25%,” with “99% of buyers entitled to unconditional exemption.”
The assertion dismissed fears of a market sell-off, noting that “any disposals in December 2025 would have benefited from the reinvestment exemption or enhanced deductions below the brand new regulation.”
On the graduation date of the legal guidelines, Oyedele mentioned aligning strictly with accounting intervals “takes a slim view of the advanced transition points” concerned in a wholesale tax reform, which spans a number of intervals, audits, deductions, credit, and penalties.
Relating to oblique switch of shares, the assertion described the availability as a deliberate coverage selection aligned with world finest practices and BEPS initiatives, aimed toward closing long-exploited loopholes by multinationals.
The assertion additionally clarified that insurance coverage premiums are usually not topic to Worth Added Tax, explaining that insurance coverage doesn’t represent a taxable provide below the Nigeria Tax Act, making requires particular exemption pointless.
Addressing the definition of ‘group’, it mentioned the statutory definition applies all through the regulation except the context requires in any other case, noting that the phrase “contains” within the regulation makes the checklist of taxable individuals non-exhaustive.
On dividend taxation, the committee acknowledged that dividends from overseas corporations couldn’t be franked as a result of no Nigerian withholding tax would have been deducted, including that “the selection to deal with dividends distributed by Nigerian corporations in a different way from overseas corporations is a deliberate coverage selection, as they’re essentially totally different for tax functions.”
It additionally defined that non-residents are usually not mechanically exempt from tax registration even when earnings is topic to ultimate withholding tax, as returns serve broader compliance functions.
Different clarifications included disallowing deductions on overseas change transactions at parallel market charges, described as a fiscal coverage software to enrich financial coverage; linking tax deductibility to VAT compliance, designed as an anti-avoidance measure; and the Police Belief Fund, which expired in June 2025, making requires its repeal pointless.
Points raised on small firm exemptions have been famous to predate the brand new legal guidelines below the Finance Act 2021.
The assertion highlighted that minor clerical inconsistencies or cross-referencing gaps are already being recognized internally and shall be addressed by means of administrative steerage and rules.
“The tax reform represents a daring step towards a self-sustaining and aggressive Nigeria,” the committee mentioned, urging stakeholders to shift from “static critique to dynamic engagement” to assist efficient implementation.
The clarification comes after KPMG Nigeria’s report, which flagged potential errors, gaps, and inconsistencies within the newly gazetted tax legal guidelines, together with considerations over taxation of shares, dividend therapy, non-resident obligations, and overseas change deductions, warning that these might have an effect on companies and taxpayers.
The Chairman’s response emphasised that the reforms are deliberate, complete, and designed to enhance equity, competitiveness, and income technology.