
Taiwo Oyedele
The Nigerian government, under recent tax reform legislation, has sought to shift the tax burden away from low-income individuals and small businesses, while broadening the tax base, simplifying administration and encouraging investment.
One of the core objectives is to “not tax poverty” by exempting very low-income earners and curtailing nuisance levies. At the same time, the law introduces new reliefs and thresholds designed to bolster entrepreneurship, boost manufacturing, export-oriented firms and small and medium enterprises (SMEs). For instance, individuals earning below a defined annual threshold are now entirely exempt from personal income tax; small businesses under a turnover threshold are exempt; and certain goods and services deemed essential are zero-rated or exempt from value added tax (VAT).
In addition, the new tax law consolidates or replaces multiple levies (such as tertiary education tax, IT levy) with a simpler development levy.
Reliefs for capital expenditure and export-based companies are also introduced. Altogether, these exemptions and reliefs aim to encourage formalisation of the economy, improved compliance, and fairness in tax treatment across citizens and businesses.
Below is a full list of 50 exemptions/reliefs under the new tax reform law:
- Individuals earning up to ₦800,000 annually are exempt from personal income tax.
- Small businesses with annual turnover of ₦50 million or less are exempt from company income tax or certain income taxes.
- VAT exemption on essential goods and services, including certain food items, medical services, pharmaceuticals, educational fees etc.
- Increased threshold for tax-exempt gain from sale of shares in Nigerian companies to ₦150 million in any 12-month period (provided gains do not exceed ₦10 million) before capital gains tax applies.
- Relief / tax credit for “Economic Development Incentive” (EDI) allowing eligible companies to claim a tax credit of 5% per annum for 5 years on qualifying capital expenditure.
- Exemption / relief for free-zone companies exporting goods/services (free zones) – some tax exemptions retained for exports up to defined proportions.
- Exemption from the minimum tax (0.5% of turnover) for a company with no taxable profits under certain conditions.
- Consolidation of multiple levies into a single “Development Levy” – relief from having to compute multiple overlapping levies.
- Exemption of employees of start-ups and technology-driven service providers from certain income tax provisions (as proposed).
- Exemption for individuals in wage-employment earning under the minimum wage from personal income tax (implicitly through threshold).
- Rent relief allowance for taxpayers who pay rent (e.g., 20% of annual rent or capped amount) as a relief from taxable income.
- Increased tax-exemption threshold for compensation for loss of employment or injury raised from ₦10 million to ₦50 million.
- Exemption of certain informal traders or micro-enterprises through simplified rules and reliefs.
- No withholding tax deduction requirement on business income of small businesses under the threshold.
- Exemption for certain charitable, educational or religious organisations (non-commercial earnings) from tax.
- Relief for low-income earners via removal of tax component for those defined as poor/earning below threshold.
- Exemption of goods/services in free zones from certain taxes for export purposes (subject to conditions).
- Transitional reliefs where previous “pioneer” tax holiday incentive replaced by EDI but some transitional exemptions preserved.
- Relief/ exemption for companies whose effective tax rate falls below a minimum threshold (top-up tax applies rather than full tax).
- Exemption of certain prizes, winnings, grant or awards from tax under specific conditions (though taxed in new regime, relief may apply).
- Exemption of VAT on export of goods (subject to conditions).
- Exemption of VAT on electricity and other utilities used by low-income households (within essential goods exemption).
- Exemption of educational books and materials from VAT.
- Exemption of medical equipment and services from VAT.
- Exemption of tuition fees for education services from VAT.
- Exemption for individuals whose total income falls below the defined threshold (₦800,000). (Repeats item 1 but emphasises relief nature)
- Exemption of small business owners from paying income tax on their businesses under threshold. (Similar to item 2)
- Exemption of informal sector traders via simplified tax rule and reduced burden. (similar to item 13)
- Exemption for relief allowance on rent for employees paying rent (see item 11)
- Relief for SMEs via increased threshold from ₦25 million to ₦50 million turnover for exemption.
- Relief for capital gains where gains do not exceed certain limits (see item 4)
- Exemption of share-transfers below certain value from tax. (relates to item 4)
- Relief for eligible companies with qualifying capital expenditure purchased within five years starting production date. (item 5)
- Exemption of multiple overlapping nuisance taxes and levies – streamlining relief.
- Exemption of minimum tax for companies with no taxable profit (item 7)
- Relief via absence of withholding tax deduction requirement on small enterprises (item 14)
- Exemption of certain export earnings of free-zone companies (item 17)
- Exemption of certain goods/services from VAT to protect vulnerable populations (item 3)
- Relief to promote entrepreneurship via tax-free status for some start-ups (item 9)
- Relief for low-income households via full exemption from income tax (reinforcement of item 16)
- Exemption for non-commercial incomes of religious, charitable, and educational bodies (item 15)
- Relief via rent relief allowance for taxpayers who pay rent (item 11)
- Exemption for transfer pricing/international indirect share transfer rules with relief thresholds (item 4/19)
- Relief via increased exemption threshold for compensation for loss of employment or injury (item 12)
- Exemption of informal sector operators from certain rigid tax procedures (item 13)
- Relief via consolidation of levies to reduce compliance burdens (item 8/34)
- Exemption of low-income wage earners (item 10)
- Relief for encouraging export-oriented firms via tax exemptions (item 17)
- Exemption of goods in free zones from some taxes for export to customs territory (item 6/17)
- Relief for eligible capital expenditure via tax credit (item 5/33)
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