Filing season in 2026 will come with tighter scrutiny as new provisions under the Nigeria Tax Act (NTA) and the Nigeria Tax Administration Act (NTAA) reshape how companies calculate liabilities, submit returns, and maintain documentation.
For businesses, compliance can no longer rely on legacy bookkeeping practices. Here are five key provisions shaping corporate tax filings in 2026.
1. 15% Minimum Effective Tax Rate and Top-Up Tax
Section 57(1)(a) of the NTA introduces a minimum effective tax rate of 15 percent for certain large domestic companies and multinational enterprises.
If a company’s effective tax rate falls below 15 percent due to incentives or capital allowances, it must pay a top-up tax.
Section 57(2) applies to:
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Companies with ₦50 billion or more in turnover
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Multinational groups with aggregate turnover of £750 million or equivalent
Covered taxes include:
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Company Income Tax
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Petroleum Profits Tax
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Hydrocarbon Taxes
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4% Development Levy
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Priority Sector Tax Credits
The rate is measured against net income in audited financial statements, excluding franked investment income and unrealised gains or losses.
Importantly, Section 6(3) extends the rule to foreign subsidiaries. If a non-resident subsidiary pays less than 15 percent tax abroad, the Nigerian parent company must settle the difference locally.
What this means:
Businesses must maintain clear records of profits, deductions, tax payments, and subsidiary contributions to demonstrate compliance and reduce audit risks.
2. Monthly Reporting and Digital Compliance
Under Sections 18, 20, and 21 of the NTAA, companies must now file monthly returns for specific revenue types, including:
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Royalties
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Activities of non-resident companies
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Certain sector-specific revenues
The reforms also expand digital reporting obligations.
Impact on businesses:
Companies in petroleum, mining, shipping, fintech, and foreign-linked operations must maintain detailed monthly records of cash flows and revenue streams. Electronic documentation that is easily retrievable will be critical.
3. Capital Gains Now Aligned with Company Income Tax
Capital gains from asset disposals are now aligned more closely with corporate income tax provisions.
This affects companies disposing of:
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Land and property
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Shares and securities
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Other capital assets
Businesses must retain documentation on acquisition cost, improvement expenses, incidental costs, and sale proceeds to properly compute gains.
Proper valuation worksheets and audit trails will be essential to support exemptions or relief claims.
4. Digital and Virtual Assets Brought into Tax Net
The NTA now recognises digital and virtual assets as taxable sources of income and gains.
This includes:
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Digital service transactions
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Virtual asset service providers
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Cryptocurrency-related activities
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Online revenue streams
Companies operating in fintech, e-commerce, cloud services, and digital payments must maintain detailed transaction logs showing:
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Dates
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Counterparties
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Transaction values
An integrated electronic filing system will simplify reporting and reduce compliance gaps.
5. Stricter VAT Documentation Rules
While VAT remains at 7.5 percent, the updated framework allows businesses to recover input VAT on services and capital assets.
However, stricter documentation requirements now apply.
To claim input VAT, companies must retain:
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Valid VAT invoices
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Contracts
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Payment vouchers
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Proof of payment
Zero-rating for exports and essential goods requires additional documentation such as:
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Bills of lading
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Export contracts
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Statutory declarations
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Evidence goods left Nigeria
Properly organised records — digital or physical — will reduce disputes with tax authorities.
Compliance in 2026: No Room for Old Assumptions
Preparing tax returns in 2026 demands more than traditional bookkeeping. Companies must proactively review:
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Effective tax rate calculations
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Monthly reporting systems
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Subsidiary tax structures
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VAT input documentation
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Digital asset transaction logs
Businesses that adjust early to the evolving framework under the Nigeria Tax Act and Nigeria Tax Administration Act will be better positioned to file accurate returns and withstand regulatory scrutiny.
