48 Hours In — And the Crisis Has Changed Shape
Nigeria is no longer debating whether to implement its biggest tax overhaul in decades.
It is now grappling with a more dangerous question:
Which law is actually being enforced?
Since the new tax regime took effect on January 1, 2026, allegations that the gazetted Acts differ from what the National Assembly passed have escalated into a credibility crisis—one unfolding after enforcement has already begun.
This timing changes everything.
From Reform to Rule-of-Law Question
The controversy centres on claims that certain provisions appearing in the gazetted versions of the tax Acts were either altered, expanded, or insufficiently reconciled with the texts approved by lawmakers.
Critics argue that once enforcement begins, any doubt about legislative integrity becomes an enforcement problem, not a procedural footnote.
In plain terms: Nigerians are being asked to comply with laws whose final form is being questioned after they have taken effect.
Tinubu’s Position: Enforce First, Clarify Along the Way
President Bola Tinubu has maintained that the reforms must proceed, describing them as essential to Nigeria’s fiscal survival and long-term stability.
His administration argues that:
- Nigeria’s tax-to-GDP ratio remains unsustainably low
- Revenue mobilisation cannot wait
- Any concerns can be addressed without suspending enforcement
This approach is consistent with Tinubu’s broader economic strategy since 2023: move fast, absorb backlash, stabilise later.
But tax experts warn that taxation differs from fuel subsidy removal or FX reform—it relies heavily on voluntary legitimacy.
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Ezekwesili and the Critics: “You Cannot Enforce Doubt”
Former World Bank vice president Oby Ezekwesili has emerged as a leading critic, calling for an immediate suspension of enforcement pending a transparent reconciliation of the disputed texts.
Her argument is stark:
- Tax compliance depends on trust
- Trust collapses when citizens suspect procedural manipulation
- Enforcement under disputed law invites resistance, litigation, and backlash
In her framing, Nigeria risks turning tax reform into a constitutional dispute.
Businesses Caught in the Middle
By Day Two of implementation, confusion had already begun filtering through:
- Companies asking which version of the law to rely on
- Tax advisers warning clients to prepare for disputes
- Concerns about penalties being imposed under contested provisions
For businesses, uncertainty is not neutral—it is costly.
Every unresolved clause becomes a future court case.
National Assembly’s Late Intervention
Facing mounting pressure, the National Assembly has moved to release certified copies of the assented bills, a step intended to reassure the public and clarify discrepancies.
While helpful, the move raises an uncomfortable implication:
Why was this not done before enforcement began?
In legislative terms, this is damage control—not prevention.
The Machiavellian Fear Beneath the Surface
This is where the critics’ concern sharpens.
If governments can:
- Rush implementation,
- Downplay discrepancies, and
- Rely on enforcement momentum to override procedural doubts,
then legality risks becoming a technicality corrected after compliance is compelled.
That fear—not the tax rates themselves—is what is fuelling public unease.
What’s Already Happening on the Ground
- Compliance uncertainty among SMEs
- Advisory firms urging caution clauses in filings
- Early signs of selective enforcement discretion
- Growing calls for judicial interpretation
The reform is live—but so is resistance.
Credibility recovery requires more than statements.
What the Clean Fix Looks Like
Minimum corrective steps:
- Publish certified assented texts in full
- Release a clause-by-clause reconciliation with gazetted versions
- Explain how any divergence occurred
- Pause punitive enforcement until clarity is restored
Anything less risks turning reform into confrontation.
Why This Matters Now
Two days in, Nigeria stands at a fork:
- Enforce fast and risk backlash, or
- Clarify law and rebuild trust, even at short-term cost
Tax reform is not just about revenue.
It is about the relationship between the state and the citizen.
That relationship is being tested—right now.