The controversy surrounding Nigeria’s newly assented 2025 Tax Acts has intensified following allegations by the African Democratic Congress (ADC) Youth Wing that critical provisions in the law were neither properly debated nor aligned with constitutional safeguards.
At the centre of the dispute are two clauses and an international data-sharing agreement which critics say fundamentally alter the balance between revenue enforcement and citizens’ rights.
The background
President Bola Ahmed Tinubu recently signed the 2025 Tax Bills into law as part of a broader effort to reform Nigeria’s revenue system and expand the tax base. The government has argued that the reforms are necessary to stabilise public finances and reduce reliance on borrowing.
However, the ADC Youth Wing says the process and substance of the law raise serious legal and economic concerns, prompting it to issue a seven-day ultimatum to the presidency demanding suspension of the law’s implementation .
Section 41(8): The disputed “appeal deposit”
One of the most contentious provisions is Section 41(8), which requires taxpayers to pay 20 per cent of an assessed tax liability before they can challenge it in court or before a tax tribunal.
According to the ADC Youth Wing, this requirement effectively blocks access to justice, especially for small businesses and low-income taxpayers who may lack the funds to make such deposits.
Legal analysts note that while pre-conditions for tax appeals exist in some jurisdictions, they are usually designed to prevent frivolous litigation, not to deter legitimate challenges. Critics argue that in Nigeria’s current economic climate, the provision could discourage taxpayers from exercising their right to contest disputed assessments.
Section 60: Expanded enforcement powers
Another flashpoint is Section 60 of the tax framework, which the youth wing says grants arrest powers to tax officials.
The group argues that this provision creates a “fiscal police” structure without adequate safeguards, raising fears of abuse, harassment, and intimidation of taxpayers.
Supporters of stronger enforcement powers maintain that tax evasion remains widespread and that authorities need effective tools to ensure compliance. Opponents counter that arrest powers should remain the exclusive preserve of law enforcement agencies and only be exercised with judicial oversight.
Allegations of legislative irregularities
Beyond the substance of the clauses, the ADC Youth Wing alleges that Sections 41(8) and 60 were inserted into the final gazetted version of the law without being voted on during plenary sessions of the National Assembly.
The group described this as a breach of legislative procedure and demanded that the allegedly altered gazettes be withdrawn and replaced with the version passed by lawmakers .
The National Assembly has not publicly addressed these claims.
The FIRS–France agreement
The controversy has also drawn attention to a memorandum of understanding reportedly signed between the Federal Inland Revenue Service (FIRS) and France’s Direction Générale des Finances Publiques.
According to the ADC Youth Wing, the agreement could expose sensitive taxpayer data linked to Bank Verification Numbers and National Identification Numbers to foreign access, raising data protection and national security concerns.
While international cooperation on tax administration is common, transparency advocates argue that such agreements must be clearly defined and subjected to public scrutiny, particularly where citizens’ personal data is involved.
Why youths are at the forefront
The youth wing says the tax law disproportionately affects young Nigerians, many of whom operate small and informal businesses already struggling with inflation, weak purchasing power, and limited access to credit.
It also pointed to what it described as low budgetary allocations to youth development compared to government spending on overheads, arguing that the tax framework could further shrink economic opportunities for young people .
What happens next
The group has given the presidency until 3 January 2026 to suspend enforcement of the tax laws, amend the disputed clauses, and annul the FIRS–France agreement.
If the demands are not met, it has threatened nationwide taxpayer strikes and coordinated protests at revenue-generating institutions.
For now, the debate has shifted from the need for tax reform to a deeper question: how to balance revenue generation with constitutional rights, transparency, and public trust in the law-making process.
