Tax Controversy 2025: Trends And Developments

Introduction

Nigeria's tax landscape is undergoing significant changes, driven by a combination of regulatory reforms, increased enforcement activities and evolving global tax standards. One of the most notable trends is the heightened scrutiny of transfer pricing (TP) compliance, with the Federal Inland Revenue Service (FIRS) ramping up TP audits to ensure that taxpayers adhere to the arm's length principle. In parallel, Nigeria is witnessing a broader shift in tax enforcement, including the introduction of advance pricing agreement (APA) guidelines, legal actions against cryptocurrency entities, and a proposed overhaul of value-added tax (VAT) distribution. There has also been an increase in the issuance of additional assessments to companies. This stems from the non-compliance of taxpayers with their self-assessment and remittance obligations. It has, however, been observed that in some cases the additional assessment and tax audits are a reactive measure,