Market Update: Five tax rules shaping 2026 business filings – Full Analysis

Filing season for 2026 will come with more scrutiny and expectations from tax authorities.

Recent provisions in the Nigeria Tax Act and the Nigeria Tax Administration Act have changed how liabilities are calculated, how returns are submitted and how supporting documents must be maintained.

For businesses, this means filings can no longer rely on old assumptions.

Here are five provisions that would shape how companies prepare returns and organise records this year.

New rules on effective tax rate and top‑up tax

Nigeria now requires certain large domestic companies and multinational enterprises to pay a minimum effective tax rate of 15 percent under Section 57(1)(a) of the Nigeria Tax Act (NTA).

If a company’s effective tax falls below this threshold, a top-up tax is due, even when incentives or capital allowances reduce liabilities.

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Section 57(2) applies to companies with N50 billion or more in turnover and multinational groups with aggregate group turnover of £750 million or its equivalent. Covered taxes include Company Income Tax, petroleum profit tax, hydrocarbon taxes, the 4 percent development levy, and priority sector tax credits.

The rate is measured against net income in audited financial statements, excluding franked investment income and unrealised gains or losses.

The law also applies to foreign subsidiaries. Section 6(3) states that if a non-resident subsidiary pays tax below 15 percent, the Nigerian parent must pay the difference locally.

For businesses, this means keeping clear records of profits, deductions, tax paid, and subsidiary contributions to show compliance. Proper documentation ensures accurate filings, supports audits, and reduces the risk of penalties.

Monthly reporting and digital compliance obligations 

The Nigeria Revenue Service (NRS) and related authorities under the Nigeria Tax Administration Act (NTAA) have introduced provisions that affect reporting for all companies.

Sections 18, 20 and 21 of the NTAA require monthly returns for specific revenue types, including royalties and activities of non‑resident companies, and support broader digital reporting obligations.

This means businesses should keep detailed monthly records, including cash flows and revenue streams, especially if they operate in sectors like petroleum, mining, shipping or have foreign operations.

Electronic records that can be readily accessed and submitted will help ensure timely and accurate filing.

Capital gains aligned with company income tax rates

Gains from the disposal of assets are now treated differently from past years. The tax act provisions now apply capital gains at rates that align with corporate income tax, and companies should maintain valuation records and calculation worksheets for disposals.

This means that for any business selling property, shares or other capital assets, records supporting the acquisition cost, improvements, incidental costs and sale proceeds must be organised and filed.

These records help demonstrate the correct computation of gains subject to tax and support claims for any exemptions or reliefs.

Digital and virtual asset transactions brought into tax net

The Tax Act recognises digital and virtual assets as taxable components of gains and income. This includes income from digital service transactions and transactions by virtual asset service providers.

The NTAA requires that companies dealing in digital transactions, including virtual currencies and other online revenue streams, keep detailed records of transactions and report them regularly to the tax authority.

For businesses operating in fintech, e‑commerce, cloud‑based services or handling digital payments, this means maintaining transaction logs that identify dates, parties to transactions and value transferred.

An electronic filing system that tracks these transactions can help ensure compliance and make it easier to support figures reported in tax filings.

Stricter documentation required for VAT input and zero rating

The law now broadens how value added tax is treated in some areas. While the VAT rate has been retained at 7.5 percent, the rules now allow businesses to recover input VAT on services and capital assets.

To support input claims, companies must retain valid VAT invoices, contracts, payment vouchers and proof of payment.

Zero‑rating also applies to specific categories of supplies such as exports, essential goods and selected services. In these cases, detailed documentation is needed to prove entitlement to zero rating, such as contracts showing export transactions, bills of lading, statutory declarations and evidence that goods left Nigeria.

Keeping these records in an organised digital or physical file can help support VAT returns and reduce the risk of disputes with the tax authority.

Preparing tax returns in 2026 requires more than following old patterns of bookkeeping. Businesses must be conscious of how new legal provisions affect their liabilities, the records they must retain and the way they demonstrate compliance.

Companies that review their internal processes early, especially around effective tax rate calculations, reporting cycles and VAT documentation, will be better positioned to file accurately and respond to any review by the authorities.