REGULATING TAX ADMINISTRATION IN NIGERIA: LEGAL AND INSTITUTIONAL CHALLENGES IN REVENUE ENFORCEMENT

Abstract

This study examines the legal and institutional frameworks governing tax administration in Nigeria, with particular focus on the Nigeria Revenue Service (NRS) and related enforcement bodies. Despite legislative reforms and the digitalisation of tax processes, persistent challenges, including limited administrative capacity, inconsistent application of rules, and weak oversight mechanisms undermine effective revenue mobilisation and compliance. The study adopts a doctrinal and comparative approach, analysing statutes, policy instruments, and judicial interpretations, while drawing lessons from regulatory models in South Africa, Kenya, and the United Kingdom. It argues that the efficacy of Nigeria’s tax administration depends not only on the clarity of statutory powers but also on structured enforcement, accountability, and the adoption of technology-driven compliance systems. Findings reveal gaps in legal authority, monitoring, and dispute resolution mechanisms, which constrain compliance and may generate friction between taxpayers and authorities. The study recommends legislative consolidation, clear delegation of powers, strengthened auditing and monitoring systems, capacity building within tax authorities, and the implementation of digital compliance tools. By situating tax regulation within broader governance and institutional effectiveness debates, the article contributes to contemporary discourse on enhancing revenue collection while safeguarding fairness, legality, and administrative integrity. These measures are critical for ensuring that tax administration is effective, equitable, and aligned with Nigeria’s evolving economic and legal framework.