Tax Administration in Nigeria: Roles, Functions, Composition and Powers of JTB, NRS (Formerly FIRS), SBIR, JSRC, LGRC, Tax Appeal Tribunal and the Taxes and Levies Act (2025 Tax Reform Guide)

On 26 June 2025, President Bola Tinubu signed into law four landmark tax reform bills that fundamentally restructured Nigeria’s tax administration landscape. These reforms, which took full effect on 1 January 2026, represent the most comprehensive overhaul of the country’s fiscal architecture in decades. The new legislation comprises the Nigeria Tax Act (NTA), the Nigeria Tax Administration Act (NTAA), the Nigeria Revenue Service (Establishment) Act, and the Joint Revenue Board (Establishment) Act.

The reform package replaces the familiar Federal Inland Revenue Service (FIRS) with the Nigeria Revenue Service (NRS), transforms the Joint Tax Board (JTB) into the Joint Revenue Board (JRB), establishes a Tax Appeal Tribunal and Office of the Tax Ombud, and introduces new frameworks for tax collection, dispute resolution, and intergovernmental coordination.

This comprehensive guide examines the roles, functions, composition, and powers of Nigeria’s tax administration bodies under the 2025 reforms. It covers the NRS, JRB, State Internal Revenue Services (SBIRs), the Tax Appeal Tribunal, and the framework established by the Taxes and Levies Act, providing businesses and individuals with a clear understanding of the new tax administration landscape.

The Pain Points: Why Tax Administration Reform Was Needed

Fragmented and Inefficient Revenue System

Nigeria’s pre-reform tax administration system was weighed down by overlapping taxes, inconsistent interpretations of tax laws, and poor data coordination. Despite modest gains in Internally Generated Revenue (IGR), the system suffered from fragmentation across federal, state, and local government levels. Data from the National Bureau of Statistics show that Nigeria’s 36 states and the FCT generated N3.63 trillion in IGR in 2024, with Lagos alone accounting for over one-third. Between 2021 and 2024, cumulative state-level IGR totalled N10.88 trillion, highlighting both revenue potential and persistent structural gaps.

Confusion Over Roles and Responsibilities

The pre-reform system lacked a clear distinction between the tax jurisdictions of different tiers of government. The Joint Tax Board (JTB) functioned largely as a coordinating forum without explicit statutory powers, limiting its effectiveness in harmonising tax administration across the federation.

Weak Dispute Resolution Mechanisms

Taxpayers faced uncertainty and delays in resolving disputes with tax authorities. The Tax Appeal Tribunal’s tenure of commissioners expired in July 2024, leaving the Tribunal unable to adjudicate tax matters for a significant period. The system lacked a clear pathway for objections and appeals, creating confusion for taxpayers and businesses.

Inconsistent Compliance and Enforcement

Different tax authorities applied varying standards and interpretations of tax laws, leading to inconsistent compliance outcomes. Businesses operating across state lines faced duplicative assessments and conflicting regulatory requirements. Data sharing between federal and state revenue authorities was limited, enabling tax evasion and duplication.

Digital Transformation Gaps

The pre-reform system was slow to embrace digital transformation. Businesses struggled with manual processes, limited e-filing options, and inconsistent data standards across different tax authorities. The reforms aim to address these gaps through the mandatory Electronic Fiscal System (EFS) and integrated digital platforms.

Nigeria Revenue Service (NRS): The New Federal Tax Authority

Replacing FIRS with NRS

The Nigeria Revenue Service (Establishment) Act formally transitions the Federal Inland Revenue Service (FIRS) into the Nigeria Revenue Service (NRS), effective 1 January 2026. This change reflects a significant evolution in both the structure and scope of tax administration at the federal level.

Mandate and Powers

The NRS is mandated to:

• Administer and enforce all federal tax laws and collect revenues accruing to the Federation.

• Assess and account for taxes, levies, and charges imposed by federal legislation.

• Enforce compliance, including powers to trace, freeze, seize, or confiscate proceeds of tax defaulters.

The NRS is now responsible for the assessment, collection, recovery, accounting, and remittance of both tax and non-tax revenues, with broader enforcement tools and a clearer mandate for collaboration with states and local governments.

Expanded Scope

Unlike its predecessor, the NRS is now empowered to operate within a broader institutional framework that encompasses both tax and select non-tax revenues such as petroleum royalties and statutory levies as well as data integration and inter-agency collaboration. This positions the NRS to perform functions necessary for effective tax administration, compliance enforcement, and digital transformation of revenue processes, including deeper integration of taxpayer data, unified registration systems, and harmonised digital platforms that reduce duplication across the three tiers of government.

Responsibility for State Revenue Assessment

Under the new framework, the NRS may also assess taxes, levies, and fees for states, the Federal Capital Territory (FCT), and local governments upon request. This delegation mechanism has been a source of debate, with some critics arguing that it undermines fiscal federalism by making state revenue authorities subservient to the federal agency.

Joint Revenue Board (JRB): Replacing the Joint Tax Board

Transformation from JTB to JRB

The Joint Revenue Board of Nigeria (Establishment) Act replaces the long-standing Joint Tax Board (JTB) with the Joint Revenue Board (JRB), now backed by explicit statutory powers. At the JTB’s 158th meeting in Abuja on December 10, 2025, Chairman Zacch Adedeji described the transition as marking more than a name change: “The new brand identity represents renewal, transformation, and our collective commitment to excellence in revenue administration”.

Mandate and Functions

The JRB holds a wider mandate than its predecessor, including:

• Driving harmonisation of tax administration across the federation

• Supervising data standards

• Helping resolve inter-governmental revenue disputes

• Providing a legal and institutional framework for the harmonisation and coordination of revenue administration in Nigeria

• Providing a mechanism for efficient tax dispute resolution

• Promoting and safeguarding the rights of taxpayers

Composition

The Joint Revenue Board is made up of representatives from the State Revenue Services, the NRS, and relevant stakeholders.

Key Priorities

One of the Board’s priorities is the rollout of a unified national taxpayer database under the Tax ID Project. The JRB is already working with state revenue authorities to harmonise taxpayer records using foundational identifiers such as the National Identification Number (NIN) and company registration numbers. The goal is to ensure that every individual and corporate taxpayer is traceable across federal, state, and local revenue systems, reducing evasion, duplication, and conflicting assessments.

The JRB is also working to harmonise taxes, levies, and rates across the country, with chairmen of the Internal Revenue Services who are members of the board already driving the domestication of a uniform tax and levy Act in their respective states.

State and Local Revenue Authorities: SBIR, JSRC, and LGRC

State Internal Revenue Services (SBIRs)

Under the NTAA, State and FCT tax authorities retain powers over personal income tax for resident individuals (excluding military and diplomatic personnel) and local taxes. The reforms make State Internal Revenue Services (SIRS) autonomous.

Fiscal Federalism Framework

The Taxes and Levies (Approved Lists for Collection) Act 1998 continues to demarcate fiscal federalism in terms of functions conferred on the three components of government. The reforms aim to clearly distinguish the tax jurisdictions of different tiers of government, with the NRS administering corporate income tax, VAT, taxes on petroleum operations, non-resident taxation, and national tax incentives.

The Delegation Debate

The power of the NRS to collect all revenues under Section 4(1) of the Nigeria Revenue Service Establishment Act has been a subject of debate. Critics argue that this creates a potential for interference with the functions of SBIRS, FCT, and local government revenue committees, undermining fiscal federalism. The argument is that the three tiers of government should work independently in their areas of jurisdiction, as provided by the Taxes and Levies Act 1998.

Uniform Tax and Levy Act

The JRB is working with state revenue authorities to domesticate a uniform tax and levy Act in their respective states, to harmonise taxes, levies, and rates across the country.

Tax Appeal Tribunal (TAT): Composition and Powers

Establishment and Composition

The Tax Appeal Tribunal was established pursuant to Section 59 of the Federal Inland Revenue Service (FIRS) Act of 2007, and its proceedings are guided by the Tax Appeal Tribunal Procedure Rules. Under the Joint Revenue Board of Nigeria (Establishment) Act 2025, the Tribunal consists of five members (referred to as “Tax Appeal Commissioners”) appointed by the Minister.

Key composition details:

• Chairman: 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.

• Quorum: The quorum at any sitting of the Tribunal shall be three members.

• Presiding: The Chairman presides at every sitting of the Tribunal; in his absence, the members appoint one of them to be Chairman.

Territorial Jurisdiction

The Tax Appeal Tribunal has tribunals across the six geopolitical zones as well as Lagos State and the Federal Capital Territory, Abuja.

Jurisdiction Under the New Regime

Section 29 of the JRBA unequivocally grants the Tax Appeal Tribunal jurisdiction over disputes emanating from the Nigeria Tax Act, the Nigeria Tax Administration Act, tax laws of the National Assembly, and importantly, laws from the Houses of Assembly of States.

This represents a significant expansion from the historical position that disputes arising under state-enacted tax laws fall exclusively within the jurisdiction of State High Courts. The expansive language used in the Tax Reform Acts remodels the TAT from a forum for federal disputes to a significantly more encompassing central hub for all tax disputes.

Potential Overlap with State High Courts

Section 272 of the Constitution grants State High Courts jurisdiction over disputes emanating from state laws. Section 29 of the JRBA thus creates overlapping jurisdiction. How the TAT displaces State High Courts’ jurisdiction, if at all, will be determined by the courts in early cases.

Dispute Resolution Under the NTAA 2025

The Objection Process

Under the NTAA 2025, a formal pathway for a merits-based challenge has been established. The process is as follows:

Step 1: The Assessment – The tax authority issues an assessment.

Step 2: The Objection – The taxpayer must lodge a written notice of objection within 30 days of the assessment. The objection must contain precise, substantive details: the specific issue disputed, the exact monetary values, the amendment proposed, and the justification for the amendment.

Step 3: Tax Authority Response – The tax authority must respond to the objection within 90 days. If the tax authority fails to respond within this period, the objection will be upheld in the taxpayer’s favour.

Note: Nigerian jurisprudence includes every calendar day, including weekends and public holidays, in the computation of the 90-day limit. Tax officials will face immense pressure to promptly review and revise assessments.

Step 4: Appeal to TAT – Where the disagreement persists after the tax authority’s decision on the objection, the taxpayer may seek recourse at the Tax Appeal Tribunal.

Step 5: Appeal to Federal High Court – Under Section 41(8) & (9) NTAA, dissatisfied parties may subsequently appeal the TAT’s decision solely on points of law to the Federal High Court, followed by the Court of Appeal, and finally the Supreme Court.

Office of the Tax Ombud

The Tax Reform Acts have also created the Office of the Tax Ombud, an independent body to review or settle complaints concerning taxes, levies, fees, or other regulatory charges.

The Taxes and Levies Act Framework

Fiscal Federalism Under the Taxes and Levies Act

The Taxes and Levies (Approved Lists for Collection) Act 1998 clearly demarcated fiscal federalism in terms of functions conferred on the three components of government in Nigeria. The new Taxation Acts did not see anything wrong with the arrogation of almost all powers to NRS, making SBIRS, FCT, LGAs revenue committees subservient—a move that some critics describe as a “gradual movement to unitary taxation in a federal democracy”.

VAT Allocation Under the Reforms

The Acts increase state and local government area VAT allocations to 55% and 35%, respectively, while decreasing the Federal Government’s share from 15% to 10%. Fifty percent of the VAT revenue assigned to states and local governments is shared on the basis of equality, 20% is shared based on population, and the remaining 30% is shared based on place of consumption.

Concerns About Centralisation

Critics argue that centralising all revenues may have temporary advantages to the current government, but not for too long. The concerns include:

• The NRS’s role in assessing revenue for states and LGAs upon request creates potential for interference.

• The system is described as “unitary taxation” rather than fiscal federalism.

• The reforms de-emphasise all other revenue authorities in preference to what the authors want to substitute.

How Qeeva Advisory Helps with Tax Administration Compliance

At Qeeva Advisory, we understand that navigating the new tax administration landscape under the NTAA 2025 can be complex. Our team of experienced professionals helps Nigerian businesses and individuals understand their tax obligations, manage compliance requirements, and resolve disputes with tax authorities.

Our Core Services

Advisory Services Nigeria – Our advisory professionals help you understand your tax obligations under the NTA 2025 and NTAA 2025, including registration requirements, filing deadlines, and compliance obligations.

Tax Strategies and Planning – We help you structure your business to optimize tax outcomes, manage tax risks, and ensure compliance with federal and state tax laws.

Regulatory Compliance – We ensure your business meets all filing requirements, including TIN registration, tax returns, and e-filing obligations.

Bookkeeping Services – Accurate records are essential for tax compliance. Our bookkeeping services ensure your financial records are accurate and complete.

Risk Management – We help you identify and manage risks associated with tax administration, including audit risks, dispute risks, and non-compliance penalties.

Our Service Methodology for Tax Administration

Step 1: Registration and TIN Compliance – We help you obtain and maintain Tax Identification Numbers (TIN) for your business and ensure compliance with registration requirements.

Step 2: Tax Return Preparation and Filing – We help you prepare and file accurate tax returns, including VAT, CIT, and PIT, ensuring compliance with the Electronic Fiscal System (EFS).

Step 3: Audit and Assessment Support – We provide support during tax audits, assessment reviews, and compliance checks by the NRS, state revenue services, or other tax authorities.

Step 4: Dispute Resolution – If you face disputes with tax authorities, we provide expert representation before the Tax Appeal Tribunal, Federal High Court, or through alternative dispute resolution mechanisms.

Step 5: Tax Ombud Engagement – We help you engage with the Office of the Tax Ombud to review or settle complaints concerning taxes, levies, fees, or other regulatory charges.

Frequently Asked Questions

Q: What is the Nigeria Revenue Service (NRS)?
A: The NRS is the new federal tax authority that replaced the Federal Inland Revenue Service (FIRS) effective 1 January 2026. It is responsible for the assessment, collection, recovery, accounting, and remittance of federal tax and non-tax revenues.

Q: What is the Joint Revenue Board (JRB)?
A: The JRB replaced the Joint Tax Board (JTB) under the 2025 reforms. It is a platform for collaborative engagement amongst tax authorities, responsible for harmonising tax administration, supervising data standards, and resolving inter-governmental revenue disputes.

Q: What is the Tax Appeal Tribunal?
A: The Tax Appeal Tribunal is the primary forum for tax dispute resolution in Nigeria. It has jurisdiction over disputes under the NTA, NTAA, federal tax laws, and state tax laws.

Q: What are the timelines for tax objections?
A: A taxpayer must lodge a written objection within 30 days of an assessment. The tax authority must respond within 90 days, or the objection is upheld in the taxpayer’s favour.

Q: Who has jurisdiction over tax disputes?
A: The Tax Appeal Tribunal has jurisdiction over all tax disputes under federal and state tax laws. A subsequent appeal solely on points of law may be made to the Federal High Court, then the Court of Appeal, and finally the Supreme Court.

Q: What is the Tax Ombud?
A: The Office of the Tax Ombud is an independent body established to review or settle complaints concerning taxes, levies, fees, or other regulatory charges.

Q: What is the Tax ID Project?
A: The Tax ID Project is a JRB initiative to create a unified national taxpayer database using foundational identifiers such as NIN and company registration numbers, ensuring every taxpayer is traceable across federal, state, and local revenue systems.

Q: How are VAT revenues allocated under the new reforms?
A: State and local government areas receive 55% and 35% of VAT revenues respectively, while the Federal Government’s share is reduced to 10%. Fifty percent of state and local VAT is shared based on equality, 20% based on population, and 30% based on place of consumption.

The Bottom Line

The 2025 tax administration reforms represent the most comprehensive overhaul of Nigeria’s fiscal architecture in decades. The transformation introduces new institutions, enhanced powers, clearer procedures, and stronger compliance requirements.

Key Takeaways:

Understand the New Institutions: FIRS is now NRS, JTB is now JRB, and the Tax Appeal Tribunal and Office of the Tax Ombud are established with clear mandates.

Know Your Obligations: The NTAA mandates TIN registration for all taxpayers, digital filing through the Electronic Fiscal System (EFS), and quarterly reporting for financial institutions.

Timelines Are Strict: Objections must be filed within 30 days of assessment, and tax authorities must respond within 90 days.

Penalties Are Significant: Late filing attracts ₦100,000 in the first month and ₦50,000 for each subsequent month, with interest at the CBN’s Monetary Policy Rate. Non-compliance with technology deployment can attract fines up to ₦5 million.

Fiscal Federalism is Evolving: While state and local governments receive increased VAT allocations, the NRS retains significant powers over revenue assessment and collection.

Dispute Resolution is Clearer: The new framework provides a clear pathway from objection to the Tax Appeal Tribunal to the Federal High Court, Court of Appeal, and Supreme Court.

Your job is to be prepared. Understand the new tax administration landscape. Register for TIN. File returns on time. Maintain proper documentation. Seek professional guidance.

With the right approach and the right partner, you can turn tax administration from a compliance burden into a strategic advantage for transparent and efficient tax management.

Suggested Reading from Our Blog

VAT & Nigeria 2025 Tax Reforms: Key Changes for Businesses – Understand VAT reforms under NTA 2025.

VAT Under The NTA 2025: What Digital Platforms And Fintechs Need To Know – Specific guidance for digital businesses.

Regulatory Compliance In Nigeria – Comprehensive overview of tax compliance requirements.

Tax Strategies and Planning – Structure your business to optimize your tax position.

Business Restructuring & Asset Transfers Under NTA 2025 – Guidance on restructuring transactions.

Reference Links / Sources

Regfollower – President approves four new tax reform bills – Summary of the four reform laws, effective date, and institutional changes

NALTF – National Assembly Library tax dialogue with NRS – Clarification on NRS transition, NTAA provisions, and Digital Identity requirements

Punch – Tax reform centralised collection undermines federalism – Analysis of NRS powers over state revenue, fiscal federalism concerns, and Taxes and Levies Act

Tax Appeal Tribunal – FG swears in Tax Appeal Commissioners – Details on TAT establishment, composition, and jurisdictional coverage

Lexology – Key provisions of the 2025 tax reform acts – VAT allocation changes, penalties, and enforcement provisions

NESG – A New Fiscal Framework: Key Provisions of the 2025 Tax Reform Laws – Comprehensive analysis of NRS mandate, NTAA provisions, TIN requirements, and enforcement powers

BusinessDay – NRS and JRB replace FIRS and JTB – Details on JRB mandate, Tax ID Project, and state revenue coordination

BusinessDay – The future of tax dispute resolution in Nigeria (Part I) – Detailed explanation of objection process, TAT jurisdiction, and dispute resolution timelines

Lexology – Discourse of key provisions of the tax reform acts – JRB composition, Tax Ombud functions, and tax collection framework

NaijaNews – FIRS signs MoU on digital tax administration – JTB to JRB transition, Tax ID Project, and uniform tax Act domestication

LawGlobal Hub – Section 24 Joint Revenue Board of Nigeria (Establishment) Act 2025 – Legal text on Tax Appeal Tribunal composition, quorum, and Chairman qualifications

Let’s Talk About Your Tax Administration Needs

Navigating tax administration under the NTAA 2025 can be complex. At Qeeva Advisory, we understand the challenges faced by Nigerian businesses and individuals in understanding tax obligations, complying with new requirements, and resolving disputes.

Whether you need help with registration, tax return filing, or dispute resolution, we are here to support you.

📞 Call us: (+234) 802 320 0801, (+234) 807 576 5799

📧 Email: info@qeeva.com

📍 Visit us: 5, Ishola Bello Close, Off Iyalla Street, Alausa, Ikeja, Lagos, Nigeria

Contact us today to schedule a consultation. Let us help you navigate tax administration with confidence.

Your journey to tax compliance starts with a conversation. Let’s talk.