IMPLEMENTING THE UNIFIED TAX IDENTIFICATION SYSTEM: LEGAL AND ADMINISTRATIVE CHALLENGES IN NIGERIA’S NEW TAX ARCHITECTURE

Abstract

The unification of tax identification in Nigeria marks a watershed in the country’s fiscal and legal landscape, particularly with the enactment of the Nigeria Tax Administration Act, 2025, the Nigeria Tax Act, 2025, the Nigeria Revenue Service (Establishment) Act, 2025, and the Joint Revenue Board of Nigeria (Establishment) Act, 2025. These legislative instruments establish a new tax architecture designed to harmonize taxpayer data, minimize multiplicity of taxation, and enhance efficiency in revenue collection across federal, state, and local levels. Central to this reform is the Unified Tax Identification Number (UTIN), a system aimed at streamlining tax administration, broadening the tax base, and ensuring transparency in compliance and enforcement. However, the legal and administrative challenges of implementing the UTIN remain profound. Issues of institutional overlap, federalism tensions, weak digital infrastructure, taxpayers’ rights protection, and the potential for double taxation persist despite legislative innovations. This paper interrogates these challenges within the framework of Nigeria’s fiscal federalism, examining how the new Acts attempt to resolve jurisdictional conflicts, strengthen intergovernmental cooperation through the Joint Revenue Board of Nigeria, and introduce mechanisms for dispute resolution and accountability. By critically assessing the opportunities and pitfalls of the new tax regime, the paper argues that while the UTIN is a progressive step toward a modern and integrated tax system, its effectiveness will depend on political will, robust institutional frameworks, and the protection of taxpayers’ rights within the rule of law.