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• Says digital records, tax planning now critical
Nigeria’s new tax regime demands a rethink of how small and medium-sized enterprises (SMEs) record transactions, manage finances and make investment decisions, as digital compliance and tax planning move from the back office to the centre of business operations.
Tax expert and immediate past President of the Chartered Institute of Taxation of Nigeria (CITN), Samuel Agbeluyi, warned that businesses could no longer treat tax as a year-end affair, saying the new regime demands digital records capable of proving every tax position they take.
Agbeluyi spoke at the Institute of Change Management (ICM) Annual Conference in Lagos, where he delivered a presentation titled, “Navigating the Nigerian Tax Act: Unlocking SME Growth, Digital Compliance and Incentivised Investments.”
He said the critical question for businesses was no longer simply whether they had paid their taxes, but whether they had the records, systems and evidence to demonstrate that their tax positions were correct.
“Can our tax position be digitally demonstrated?” he said should become a central management question for businesses.
Under the new regime, Agbeluyi said, compliance must become part of everyday business operations, from registration, invoicing and record-keeping to reconciliation, filing, payment and retention of supporting evidence.
“The objective is not simply to pay the right amount of tax. It is to understand the rules well enough to make better business decisions, capture legitimate opportunities and build a business that can grow sustainably within the law,” he said.
Agbeluyi identified the Nigeria Tax Act 2025, Nigeria Tax Administration Act 2025, Nigeria Revenue Service Act 2025 and Joint Revenue Board Act 2025 as the four pillars of the new tax architecture.
According to him, the reforms are designed to improve clarity and predictability, deepen the use of technology and provide more structured channels for taxpayer support and dispute resolution.
For SMEs, however, he said one of the biggest changes would be the growing importance of digital records.
Businesses that still depend heavily on manual sales records, mix personal and corporate accounts, issue inconsistent invoices or fail to regularly reconcile transactions could expose themselves to audit and compliance risks.
Agbeluyi advised SMEs to maintain a complete digital trail linking sales and invoices to bank receipts, accounting records, tax returns and payments, backed by contracts, expense documents, payroll and VAT records, asset registers and tax certificates.
He also warned that expansion could bring new tax obligations, making it necessary for businesses to continually review their status as turnover, assets and operations grow.
“Growth should trigger a tax review before it triggers a tax problem,” he said.
Agbeluyi urged SMEs to continually assess their turnover, assets, VAT position, payroll obligations, deductible expenses, available investment incentives and record-keeping systems.
The workshop also drew attention to the N100 million turnover threshold for small-business VAT treatment, advising eligible businesses to carefully assess their commercial circumstances and capacity to meet the accompanying compliance requirements before voluntarily opting into the VAT system.
Agbeluyi also urged business owners to separate personal and corporate finances, noting that owners could remain liable to personal income tax on applicable income even where their companies had separate corporate tax obligations.
Beyond compliance, he said the new regime could open opportunities for businesses that understand and legitimately utilise available tax incentives, including those associated with agriculture and production, qualifying startups, employment creation, capital investment and expansion.
He, however, cautioned businesses against making investment decisions merely on the assumption that an incentive would apply.
Companies, he said, should first establish their eligibility, understand the conditions attached, maintain the necessary documentation and determine how the benefit would be reflected in their tax compliance.
Agbeluyi also warned that the disposal of valuable business assets could have tax consequences, urging companies to assess their exposure before selling land, commercial buildings, vehicles, shares, digital assets or intellectual property.
According to him, businesses must move away from seeing taxation merely as a cost to be settled after decisions have been taken and instead factor it into investment, expansion, employment and asset-disposal decisions from the outset.
He added that taxpayers could challenge assessments they considered unfair or incorrect through written objections, the Tax Appeal Tribunal and the courts, as well as alternative dispute-resolution and taxpayer-support mechanisms.
For SMEs navigating the new regime, Agbeluyi prescribed four priorities: understand applicable thresholds, maintain reliable records, digitalise compliance processes and assess tax implications before major business transactions.
