For years, Nigeria’s tax system has struggled to keep pace with the realities of a modern economy. Outdated laws, inconsistent interpretations and fragmented enforcement structures have created a climate of uncertainty for businesses and individuals alike.
The resulting mix of distrust, inefficiency and conflict has long signalled the need for systemic reform. That long-awaited shift begins on 1 January 2026 with the implementation of a new suite of tax reforms, most notably the Joint Revenue Board (Establishment) Act 2024, which creates three institutions: the Joint Revenue Board, the Tax Appeal Tribunal and, perhaps most significantly, the Office of the Tax Ombud.
Meaningful evolution
The introduction of a tax ombud marks a meaningful evolution in Nigeria’s tax governance framework. It is designed to function as a neutral, independent voice, one that can give taxpayers a fair hearing, hold revenue authorities accountable, and help rebuild confidence in a system many consider burdensome or arbitrary.
A central oversight body that can interpret procedural fairness is not just useful but essential
Its creation acknowledges a longstanding problem: taxpayers have frequently faced inconsistent assessments, excessive penalties, overlapping audits and conflicting interpretations of tax obligations across federal, state, local and regulatory bodies. These issues have often deterred investment and driven otherwise compliant taxpayers into disputes or avoidance. In a system where multiple tiers of government levy taxes simultaneously, a central oversight body that can interpret procedural fairness and intervene in cases of abuse is not just useful but essential.
Nigeria’s move aligns with global trends. Several countries, from South Africa and Tanzania to Canada and across the European Union, have long relied on tax ombud offices to promote fairness, strengthen administrative justice and improve compliance, while Uganda has begun consultations.
Layer of accountability
For Nigeria, the creation of such an office also addresses a pervasive challenge: taxpayers’ limited awareness of their rights. Many individuals and SMEs remain unclear about the boundaries of tax authorities’ powers, leaving them vulnerable to intimidation, improper assessments or unlawful enforcement practices. An ombud with the mandate to investigate complaints, mediate disputes, issue public guidance and even initiate legal action on behalf of taxpayers at no cost has the potential to shift this dynamic.
It creates a protective mechanism for SMEs who lack resources to challenge unfair treatment
The functions of the tax ombud, as set out in the act, are broad. The office may receive and investigate complaints concerning taxes, levies, customs, excise duties, regulatory fees and administrative abuses. It can mediate between taxpayers and revenue authorities, review systemic problems, issue guidelines, educate the public and advocate for fair treatment. Although it cannot assess taxes or determine liability, its role as an impartial mediator and watchdog introduces an important layer of accountability previously missing from the system.
The potential benefits are significant. An ombud can restore a measure of trust, encouraging taxpayers to comply voluntarily when they know disputes will be handled fairly. It can reduce the number of cases escalating to the Tax Appeal Tribunal, saving time, reducing costs and minimising disruption to businesses. It also creates a protective mechanism for SMEs and vulnerable taxpayers who often lack the resources to challenge unfair treatment. For the broader economy, the introduction of predictability and fairness improves the investment climate and enhances Nigeria’s competitiveness.
Limited jurisdiction
Still, the new system is not without risks. The ombud’s recommendations are not enforceable, meaning revenue agencies may ignore or delay compliance. Its jurisdiction is limited to procedural fairness and does not extend to interpreting tax laws or determining liability constraints that could weaken its impact.
Filing a complaint does not automatically suspend enforcement actions, leaving taxpayers exposed even while seeking redress. The office is also optional; taxpayers can bypass it entirely and proceed directly to the tribunal, which may reduce the ombud’s relevance.
Finally, resistance from revenue bodies accustomed to minimal external oversight could impede effective investigations.
Safeguards required
To ensure the ombud becomes a meaningful institution rather than a symbolic gesture, several elements must be deliberately established. Clear mechanisms for enforcing or escalating its recommendations should be institutionalised, with defined timelines and consequences for non-compliance.
The office must enjoy full financial and operational independence, protected from political influence or bureaucratic interference. Access to accurate and complete information from all revenue authorities must be guaranteed. Public awareness campaigns are necessary to educate taxpayers about their rights and how to lodge complaints.
The new sheriff in Nigeria’s tax landscape risks becoming a mere figurehead
The ombud should also be positioned as the first step in tax dispute resolution, working in alignment with the Tax Appeal Tribunal. Digital platforms for case management, as well as highly skilled investigators and mediators, will be critical to ensuring efficiency and credibility.
Important milestone
The establishment of the tax ombud is an important milestone in Nigeria’s pursuit of a transparent, predictable and business-friendly tax environment. If empowered and effectively implemented, it can ease longstanding tensions between taxpayers and the state, improve voluntary compliance, and strengthen the integrity of tax administration.
But the institution must be supported by robust enforcement, strong cooperation across agencies and widespread public education. Otherwise, the new sheriff in Nigeria’s tax landscape risks becoming a mere figurehead – a ‘paper tiger’ unable to deliver the justice and fairness it promises. The coming years will determine whether this reform delivers the systemic change the country urgently needs.
