January 2026 Tax Rollout In Jeopardy As FG Is Sued

… Ekiti, Anambra, Zamfara Domesticate Nigeria Tax Administration Act

… Court To Rule On Injunction Bid January 5

Daud Olatunji 

As Nigeria’s sweeping tax reforms gather momentum across the states, the Federal Government has been dragged before the Federal Capital Territory High Court, Abuja, over its plan to commence implementation of the new tax regime on January 1, 2026.

The legal challenge comes even as Ekiti, Anambra and Zamfara states have taken concrete steps to domesticate the Nigeria Tax Administration Act, signalling growing alignment with the Federal Government’s reform agenda despite mounting controversy over the laws’ legality, timing and content.

The suit was filed by the Incorporated Trustees of the African Initiative for Abuse Public Trustees, who are questioning the legality and readiness of the new tax laws ahead of their proposed commencement date.

In the action, the Federal Republic of Nigeria, President Bola Tinubu, the Attorney General of the Federation, the President of the Senate, the Speaker of the House of Representatives and the National Assembly Management are listed as respondents.

The plaintiffs are seeking an order of interim injunction restraining the Federal Government and its agencies from enforcing or giving effect to the tax laws pending the determination of the substantive suit.

According to the group, allowing the laws to take effect from January 1, 2026, while critical legal issues remain unresolved, could have “far-reaching legal and economic implications” for citizens, businesses and state governments.

In a motion ex parte filed before the court, the plaintiffs argued that they would suffer “irreparable harm” if the laws are implemented before the court rules on their validity, urging the judiciary to preserve the status quo.

Although the court declined to grant an immediate injunction, it fixed January 5, 2026, for ruling on the ex parte application, keeping the fate of the reforms under close judicial watch.

The lawsuit has further fuelled public debate over the Federal Government’s tax overhaul, which seeks to harmonise Nigeria’s fragmented tax system, eliminate multiple taxation and block revenue leakages.

Despite the legal uncertainty, some states have moved ahead to domesticate the reforms.
Ekiti State became the first in the federation to align with the new framework after Governor Biodun Oyebanji assented to the Ekiti State Revenue Administration Law, 2025, on December 23.

Zamfara State followed suit as Governor Dauda Lawal signed into law a bill repealing and re-enacting the Zamfara State Consolidated Revenue Laws, effectively bringing the state’s tax structure in line with the Nigeria Tax Administration Act.

Similarly, Anambra State Governor, Prof. Chukwuma Soludo, assented to the Anambra State Taxes, Levies and Presumptive Tax (Approved List for Collection) Law, 2025, reinforcing the growing acceptance of the reforms at the sub-national level. Soludo also signed the 2026 Anambra Appropriation Bill into law on the same day.

The domestication of the legislation is aimed at harmonising taxes and levies across federal and state governments, restricting states to an approved list of collections, and ending the burden of overlapping charges that have long plagued businesses and residents.

According to the reform framework, uniformity and transparency in tax administration are central objectives, with the new laws designed to streamline collections and improve accountability.

However, the reform process has been dogged by controversy following allegations that discrepancies exist between the tax laws passed by the National Assembly and the versions later gazetted for public use.

The allegations sparked public outrage, with several stakeholders calling for a suspension of implementation until clarity is restored.

In response, the leadership of the Senate and the House of Representatives directed the Clerk of the National Assembly, Kamoru Ogunlana, to collaborate with relevant executive agencies to re-gazette the laws to reflect the exact versions approved by lawmakers.

The tax reform package includes the Nigeria Tax Act, 2025; the Nigeria Tax Administration Act, 2025; the Joint Revenue Board of Nigeria (Establishment) Act, 2025; and the Nigeria Revenue Service (Establishment) Act, 2025.

Despite the court action and public concerns, the Federal Government has maintained that implementation will commence on January 1, 2026, insisting that states must domesticate the laws to ensure seamless enforcement.

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