Taxation is considered one of the major sources of revenue for any government or country in the world. Before a country decides to administer a tax system, it must have processed a clear picture of the scope of its tax system. The history of taxation in Nigeria dates back to the pre-colonial era before the country’s independence and before the name “Nigeria” was ever coined. Taxation in the pre-colonial era included the practice of imposing levies on members of the community for the development of the community. Modern day system of tax generation also follows this pattern and for the same purpose. The Nigeria tax system is basically structured as a tool for revenue generation. This is a legacy from the pre-independence government.
- CONCEPT OF TAXATION IN NIGERIA
The term “Taxation” has been defined by several authors. There is no specific legislative definition for tax in all our laws relating to tax. However, despite the various definitions, it is important to note that a proper definition of tax must be supported by legislation and must be a deduction that gives to treasury of the authorities concerned with revenue generally.
According to the Oxford English Dictionary, a Tax is defined as “a compulsory contribution to the support of government levied on persons property, income, commodities, transactions, etc., now at a fixed rate proportionate to the amount on which the contributions is levied”. For a simplified definition, the Oxford Advanced Learner’s Dictionary defined a Tax as “money that you have to pay to the government so that it can pay for public services”. It further concluded that “people pay tax according to their income and businesses pay tax according to their profits. Tax is also often paid on goods and services.”
The term “Tax” was further judicially defined in the Australian case of Mathews v Chicory Marketing Board as “a compulsory exaction of money by a public authority for public purpose or raising money for the purpose of government by means of contributions from individual persons”.
It is important to note the distinguishing features between Tax and other forms of compulsory contribution which bear semblance with it. The criterion of the compulsory nature of tax becomes clearer when distinguishing a tax from a charge for a government service for example. For instance, there is a difference between paying a bridge toll and paying a tax to be used for the defence of one’s country. Also, the charge must be related to the service given, and not varied according to the person’s ability to pay or to some other criterion such as the value of his/her property.
The most apt and encompassing definition of Tax is supplied in Aiyar’s Concise Law Dictionary. Tax was defined as “a compulsory exaction of money by a public authority for public purposes enforceable by law and is not payment for services rendered.”
- PRINCIPLES OF A GOOD TAX
There are certain ingredients or principles that make up a good or ideal tax. Adam Smith, a writer wrote in his book titled; “The Wealth of Nations”, describing the ingredients of an ideal tax as “cannons of taxation” while Kath Nightingale in her book titled; “Theory and Practice of Taxation” stated that a good tax must possess the following:
- SIMPLICITY: This means that a good tax system must be straightforward, simple, and coherent. The concept and principles of the tax must be understood by majority of the citizens and must be simple to operate. There must also be a consistency in the administration of the tax among the different strata/ tiers of government.
- EQUITY: An ideal tax must be administered on the principles of equity (fairness and equality). There are two types of equitable principles in the taxing system namely the horizontal equity and vertical equity. Horizontal equity is that those in equal circumstances should pay an equal amount of tax while Vertical equity means that those in unequal circumstances should pay different amount of tax. The importance of this criterion is to instill confidence in the taxpayers who will be more willing to pay their taxes if they believe that the system is fair and equal.
- CAPABILITY: This means that the tax must not be unbearable for the taxpayers. It must be within their financial capability.
- ADMINISTRATIVE EFFICIENCY: The administrative costs should not be higher than the revenue yielded. The tax must consider certain factors such as, the effects on economic incentives, and whether it is compatible with desirable international economic relations.
- CERTAINTY: The scope of the tax should be clear. This criterion also means the certainty that the tax can and will be enforced, because a tax that is easily evaded usually causes resentment and often a decline in taxpayer morality. Also, the tax which every person is bound to pay ought to be certain and not arbitrary.
- FLEXIBILITY AND STABILITY: The tax system should be flexible especially in a federal and democratic country such as Nigeria where there are always changes in government.
- NEUTRALITY: A tax must be neutral thus it must avoid distortions of the market. For instance, a selective tax, such as the sales tax, is not neutral, because it encourages the consumer to spend his money on another item rather than a taxable one.
- IMPORTANCE OF TAXATION
In an egalitarian society, the importance of tax cannot be overemphasized. The system of taxation was created to fund State institutions and projects. Also, tax can be collected directly from taxpayers which means that citizens pay taxes from their earnings. Taxes are collected indirectly by charging tax on goods and services which citizens purchase. Most countries around the world live on an established tax system that helps them pool funds for their survival.
- SOURCE OF REVENUE: Income tax is one of the major sources of revenue for the government. It raises revenue to meet government expenditure. The government expenditure which requires to be met include provision of services which the free market cannot provide such as national security, health services, education, medical research, infrastructure development and law enforcement. These are often referred to as public goods or programs. Thus, the taxes collected come back to the taxpayers in the form of social amenities.
- MEANS OF RESTRICTION: Income tax has been used to encourage and discourage some activities in the private sectors. This however depends on whether the policy of the government is towards encouraging or discouraging such activities. The tax system may thus be used for discouraging activities such as the sale of alcohol or purchase of cigarettes.
- SOCIAL EFFECTS: Taxation affects the lives of nearly everyone in a country. Personal reliefs such as aids and assistance, reliefs in respect of children and tuition i.e., scholarships and grants, reliefs on insurance policy premiums, and dependent relatives’ relief e.g., gratuities of a dead civil servant affect the social structure of the whole country. Taxation further assists in the redistribution of wealth in the society. Taxes paid are used as means to bridge the gap between the rich and the poor.
- ECONOMIC EFFECTS: Income tax has some effect on population movements and the extent of which business is carried on. A state with a low-income tax rate will have a higher rate of migrants into such a State. Also, traders and businessmen will leave States with high income tax rates or engage in various schemes of tax avoidance and tax evasions.
- BRIEF HISTORY OF TAXATION IN NIGERIA
The concept of tax has been understood and applied by man since time immemorial. This is because the idea of striving towards attaining a better society is not strange to mankind. Nigeria is still a developing country whose economy is not yet stable and efficient. The tax system of a country is essentially a derivative of its history, economic structure, and political economy.
According to M. T. Abdulrazaq in his book, “Principles and Practice of Nigerian Tax Planning and Management”,a country’s tax system for all intents and purposes emanates from its economic, political, and cultural history. Nigeria is a country with a very rich and long cultural histories which still substantially rub on general policy including the tax system. It is known that before the invasion of the Europeans in Africa especially Nigeria, the various communities that existed in the landmass that constitute the entity known as Nigeria today have their respective legal norms and way of lives.
There was no formal tax policy in Nigeria until the 1930s. Only traditional rulers had the authority to collect taxes and use them however they wanted. These rulers managed to create their own system of taxes. However, none of them managed to survive long enough to be remembered in history. Thus, before the incursion of the British into Nigeria, the idea and system of tax levying and payment was an integral part of the financial system of the Nigerian communitiesthen. Although at that period, the taxation system was largely operated on ethnical basis. Therefore, there were few communities where taxes were not levied.
Before the colonization period in Nigeria, the tax system was traced to the Northern parts of the country. The Emirs, as the political and religious leaders created a system of taxes throughout the north. The system of taxation wasentrenched on the principles of Islamic law (Shari’ah). However, the Southern part of the country was not as organized as the North. Therefore, the South did not have a centralized system of taxation. According to historical data, the parts of Nigeria that were under the Islam taxation had several forms of taxes such as:
- Zakat : A tax levied on Muslims for charitable, religious, educational and welfare purposes. It is generally used to cater for the needs of the less privileged and the needy in society.
- Jizyah: A form of tax levied on the non-Muslims who live in the Muslim communities. This was used as a payment for ensuring the safety of their lives and properties while they still reside in the Muslim community.
- Shukka-Shukka: A tax paid on all crops that were not liable to Zakat.
- Jangali: A tax levied on the heads of livestock. It was commonly known as Cattle tax.
- Kurdin Kasa: This is an agricultural tax common at the time and it was paid by farmers on all their cash crops harvested within the territory of the Emir’s province.
However, in the south, not all the communities practiced the taxing system. This is because several of the communities did not have an organized governance system like the north. Therefore, in the part of the southern communities where there was an established centralized authority, administrative machinery, and judicial institutions such as the Yoruba land and the Benin Kingdom (Western and Mid-western part of Nigeria), there was a system of taxation.
However, in other communities which do not have any centralized constituted authority, such as the Ibos, Tivs, Buras, Igbiras and Bachamas, there was little or no form of organized tax system. Taxes in the pre-colonial era were not strictly pecuniary. This means that they were not only paid in cash or kind but also in kind or through obligatory personal services also known as tribute taxes. Although, the introduction of money did not stop the use of obligatory personal service as a form of tax payment, it rather supplemented it.
The Yoruba land paid the following forms of taxes:
- Ishakole: Isha-Kole was compulsory for all members of the community. It was paid to the community leaders or chiefs.
- Owo-Ori: This form of tax was paid to the community head or kings for services provided by individuals.
The British empire tried to fight for economic dominance in the region. As a result, the British empire exploited resources and the people of Africa. After the British came into Nigeria and discovered that there was an organized government in the north and upon the introduction of the indirect rule, the British government under Lord Lugard introduced the first Income Tax law in what is today known as Nigeria in 1904 by consolidating all the various traditional taxes under the Land Revenue Proclamation of 1904. Lord Lugard was a British colonial administrator in Nigeria. He tried to harmonize and centralize the tax system in Nigeria. As a result, he implemented the Stamp Duties Proclamation in 1903. This proclamation was followed by the Native Revenue Proclamation in 1906. The Native Revenue Proclamation was created to harmonize the taxes. It created the four core principles of payment. Therefore, when a person wanted to pay taxes, he or she could just follow these questions:
- What to pay?
- Whom to pay?
- Where to pay?
- When to pay?
This procedure simplified and clarified the taxation policy in Nigeria. Those two proclamations became the first in the sequence of the taxation policies in Nigeria.
The present form of Nigeria taxation can be traced back to 1914. During that year, the Northern and Southern Directorate implemented the basics of taxation in Nigeria. In addition, it helped to start the sequence of tax ordinances in Nigeria. There was no tax law in the southern part of Nigeria until 1917 when Lord Lugard made certain changes to the law which culminated in the Native Revenue Ordinance of 1917. The Ordinance became operative in the western and mid western Nigeria in 1918 while it started operating in the eastern Nigeria in 1928. The Native Revenue Ordinance was believed to be discriminatory as it applied to only natives that lived in other parts of Nigeria other than Lagos.
Thus, in 1937, a Native Direct Taxation (Colony) Ordinance No. 41 of 1937 was passed to provide for taxes for natives living within the Lagos colony. Later, the Non-Native (Protectorate) Ordinance of 1939 was also passed to provide for taxation of non-natives. However, in 1940, the Native Revenue Ordinances of 1917, 1918 and 1928 were all later incorporated into one tax legislation that was more comprehensive known as Direct Tax Ordinance No. 4 of 1940. The Direct Taxation Ordinance of 1940 was believed to be the first major tax legislation in Nigeria. It would therefore be proper to describe it as the fore runner of Nigerian tax legislations.
Tax under the Direct Taxation Ordinance 1940 was levied on the community. The community was described in section 2 (1) of the Ordinance as comprising “any town, village or settlement, or any locality therein, including a band of nomad herdsmen; and individuals within a community.” By section 4 of the Ordinance, the income to be assessed was income from land, rents derived from land, annual profits of the produce from land which were enjoyed by the community or individual, income from employments and pensions, profits from trade or manufacture, dividends or interest, and the value of all livestock owned by individuals or community. It is worthy to note that apart from the introduction of tax over employment and pension, other items upon which tax were levied were those inherited from the earlier traditional tax system.
The importance of the Direct Taxation Ordinance in the history of income tax in Nigeria is that it was the first tax statute that applied throughout the country having consolidated all previous tax ordinances from 1907 to 1939. One of the shortcomings of the Direct Taxation Ordinance was its failure of uniformity in the administration of tax in the country. Under the Direct Taxation Ordinance, administrative officers only levied tax on the incomes of Africans throughout the country and the Europeans that lived in Federal Territory of Lagos. Thus, the Europeans living in the former regions were not subject to tax in the regions in which they were resident.
Also, another shortcoming was that the Ordinance applied to both persons and companies thus lumping together under the same law provisions for the taxation of personal and company incomes. At the time, the Nigerian tax system had a narrow national tax base and limited tax instruments, thus lacking the revenue elasticity required to meet the usual upward trend in national spending. The situations above led to the constitution of the Raisman Fiscal Commission of 1958. The Commission recommended the introduction of basic principles for taxing incomes or standardized tax principles throughout Nigeria. The recommendations from the Commission were later accepted and adopted by the National Government. These recommendations became the part of the Nigerian Constitution. The constitution formed the basis of the Income Management Act and Companies Income Tax Act in 1961 whose principles we still largely use in Nigeria today though with periodic reviews and amendments.
- CLASSIFICATIONS OF TAXATION
Since the formal introduction of tax, the system of taxation has undergone various transformation and evolution. The earliest known form of taxation was on head-to-head basis. And over time, taxation has taken several different forms.
There are two major categories of taxation depending on the object of the taxation. The different categories of taxes include the following:
- DIRECT/INDIRECT TAXATION
Taxes can be classified into either direct or indirect. The distinguishing factor between these two categories is whether the taxpayer is aware of the incidence of the tax paid.
- Direct Tax: This is a tax levied directly on the person who is expected to pay the tax. With this type of taxation, the taxpayer will be duly advised through a notification known as ‘assessment notice’ and he will also be given receipt for the tax paid. Examples of direct taxation include Personal Income Tax, Pay-As-You Earn (PAYE), Capital Gain Tax, Capital Transfer Tax, Company Income Tax, etc.,
- Indirect Tax: This is a tax collected from one person in the expectation and intention that he shall indemnify himself at the expense of another. Indirect tax is borne by a person other than the one from whom the tax is collected. Such tax is usually levied on the manufacturer but paid by consumer. The taxpayer of indirect tax is never notified, nor do they have actual knowledge of such levy. Examples of indirect tax include Value Added Tax (VAT), Stamp Duty, Customs Duty, Excise Tax, etc.
- * PROPORTIONAL, PROGRESSIVE, AND REGRESSIVE TAXATION
This classification is based on the way in which the burden of the tax is distributed among taxpayers.
- Proportional Tax: This is a kind of tax in which the amount paid as tax is directly proportionate (equal) to the amount raised (calculated) as the value of the property taxed (also known as tax base). For this, the percentage of the tax rate remains the same as the tax base increases. It is also referred to as neutral tax.
- Progressive Tax: This is the form of tax in which the percentage of the tax rate increases as the tax base of a person increases. Therefore, a person with higher income would pay a greater percentage of tax than a person who earns a lower income. The progressive tax system preaches fairness and equity by asking the richer to pay more tax than the poor.
- Regressive Tax: This is a tax whose structure is such that the percentage of tax rate paid becomes smaller as the value of the property taxed (tax base) increases. Thus, a person earning higher income pays lesser tax than a person earning lower income.
There are other miscellaneous forms of categorizing taxation. Tax may be classified based on the mode of payment of the tax. That means whether per unit or ad valorem.
UNIT or specific tax is levied on the volume of what is being taxed. Most excise duties for instance are specific in nature, e.g., Tobacco tax is charged by weight of the tobacco.
ADVALOREM tax is levied on the value of the tax base e.g., income tax could be charged at 10% to 40% depending on the level and the type of income.
The categorization of tax is an unending one. Taxation could be categorized into different categories depending on the variant used. Taxation could also be categorized based on the level of awareness of a taxpayer about the tax he is expected to pay. It could also be classified based on how the burden of the tax is spread among the inhabitants of the community. Also, it could also be categorized based on the mode of paying such tax.
- EXAMINATION OF TAXING POWERS IN THE FEDERAL REBUBLIC OF NIGERIA UNDER THE 1999 CONSTITUTION OF THE FEDERAL REPUBLIC OF NIGERIA (AS AMENDED)
MEANING OF TAXING POWER
Taxation refers to how a government or the taxing authority imposes or levies a tax on its citizens and business entities. The term “Taxing power” refers to the ability of a legal body vested with the responsibility of imposing tax liability on the taxpayers’ income. Usually, it is the Constitution that allocates these taxing powers. It could also describe a level of government’s ability to impose tax through its laws and set requirements for the proper collection and administration of the tax by either its own agency or that of another level of government. Taxation is largely statutory as seen in sections 4 and 59 of the 1999 Constitution of the Federal Republic of Nigeria (as amended) and the tax law of a nation is usually unique to it although there are similarities and common elements in the laws of various countries.
Tax can only be levied by a recognized government. Tax exhibit sovereignty and it is the responsibility of government and not individual to impose. Such power must be constitutionally derived. A tax power is not a mere power to collect taxes or levies because such powers is executive or administrative, but instead a statutory ground to impose tax. Any imposition and collection of tax outside the jurisdiction of tax statute or that is devoid of the state legislative arm approval is a self-ascribed taxing power which to that extent is null.
In Nigeria, the “taxing powers” of the government are rooted in the constitution. All the government taxing agencies also derive their powers from the legislation, therefore no agency can tax citizens if they are not authorized to do so by any valid legislation in force. The Nigerian taxing system has come a long way from the several ordinances and proclamations put in place by the British empire. The 1999 Constitution of the Federal Republic of Nigeria (as amended) in its legislative list provides for the distribution of various taxing powers across the three tiers of government with bulk of the power accorded to the Federal Government.
THE EVOLUTION OF TAXING POWERS IN NIGERIA
Nigeria operated a Unitary System of Government until 1946. With the introduction of the Richard’s Constitution in 1946, the Regions created were given some measure of administrative authority and responsibility. However, they were not autonomous. They could only legislate on certain local matters, with the sole power of taxation being under the control of the central government. By and large, when Nigeria became a Federation in 1954, the issue of division of taxing powers among regions and the central government quickly emerged.
As per Ayua (1996), the inquiry was examined at a Nigeria-protected gathering in London in 1957. At the gathering, it was concluded that the issue be alluded to a commission. Thus, the Raisman Commission was initiated to investigate the issues as regarding the distribution of taxing powers between the Regional and Federal State-run administrations and make suggestions that would guarantee a circulation. Sir Louis Chick Commission of 1953 made suggestions which were reflected in sections 155-163 of the 1954 Constitution request-in-chamber. Sir Louis Chick Commission recommended that, each of the regional legislatures should be given power to legislate on revenue matters within their region. Consequently, Finance Law was enacted in the Eastern Region. This was followed by the Western Region Income Tax Law. The aftermath of that decision was the appointment of Raisman Commission.
The Raisman Commission of 1958 made a report of its recommendation which would amongst other things, secure “that the maximum possible proportion of the income of regional governments should be in the exclusive power of those governments to levy and collect”. The commission’s recommendations were accepted and embodied in the 1960 Independence Constitution.
THE TAXING POWERS OF THE FEDERAL GOVERNMENT
Under the 1999 Constitution of the Federal Republic of Nigeria CFRN (as amended), taxing power is divided between the Federal and State Government. The 1979 Constitution brought about certain changes to the position of taxing powers in Nigeria. These changes were retained by the 1999 Constitution. The relevant portions being section 4 of the 1999 CFRN (as amended).
The 1979 and 1999 Constitutions have not done much to improve on a lot of the States in terms of allocation of financial sovereignty, with the consequence that the Federal Government maintains its strong position. Thus, under the Exclusive Legislative List, set out in part I of the Second Schedule of the 1999 Constitution, the Federal Government has exclusive jurisdiction to impose the following taxes:
- Excise Duty
- Import and Export Duty
- Companies Tax or any other type of tax on companies
- Petroleum Tax or any other tax relating to mines and minerals.
- Stamp Duties
- Incomes, profits, and capital gains taxes
- Taxes relating to trade anc4 commerce in all its ramifications.
- Communication and Tele-communication taxes e.g., radio and television licence etc.
It is important to note that the Federal Government do not only have powers over taxation as stated in the Exclusive List, but also the Concurrent Legislative List. The reason why so much tax power is given to the Federal Government is to avoid competing and conflicting tax jurisdiction and to aid the Federal Government’s higher generation of revenue to be able to meet the socio-economic responsibility of the Central government.
The various States impose various taxes on companies like capital gains tax, withholding tax, stamp duties, business premises registration fees, pools betting, Lottering, gaming and casino taxes, economic development levy, tenement rates and such other taxes. Individuals within the various states are also required to pay personal income tax, capital gains tax, stamp duties, withholding tax etc.
- ROLE OF TAXATION IN THE ECONOMIC DEVELOPMENT AND REVENUE GENERATION IN NIGERIA
Government Revenue simply means the money received by a government via taxation or from other sources like sales. It is the amount of money that a company receives during a specific period. Revenues earned by government are received from sources such as taxes levied on income, and wealth accumulation of individuals and corporations and the goods and services produced, exports, imports, non- taxable sources such as government-owned corporations’ incomes, central bank revenue and capital receipts in the form of external loans and debts from international financial institutions.
Government use revenue for the development of the country in regards of construction of roads, bridges, build homes, fix schools e.tc. In Nigeria, federally collected revenue is divided into oil revenue and non-oil revenue. Oil revenue covers all revenue generated from oil and gas activities in the country, while non-oil revenue is received from sources other than oil and gas activities.
TAXATION AND ITS ROLE IN ECONOMIC GROWTH IN NIGERIA
Economic growth is the objective of any nation either developed or developing. Economic growths are the increase in the capacity of an economy to produce goods and services, compared from one period to another. The stabilization of the economy, redistribution of incomes, provision of economic services are the major responsibilities a government owes to it citizens.
The ability of government to live up to these responsibilities depends largely on the amount of revenue generated by the government through various sources either internal or external. One of the sources being taxation. Taxation is one of the oldest means by which the cost of government is funded. Also, it is one of the instruments of repayment of public debt and boosting of public sector performance. Taxation can be used to direct or influence the consumption pattern of citizens.
Taxation can also be used to encourage or discourage investment in certain sectors of the economy. This way, the government can significantly reduce the number of “harmful”, “antisocial” but not illegal economic activities such as the purchase and sale of alcohol and cigarettes. In corollary to the above, it can be used to protect local and small businesses.
Most importantly, taxation is a major source of government revenue and tax proceeds are used to render traditional functions such as construction of roads, maintenance of law and order, national defense, regulation of trade and business to ensure social and economic maintenance, medical research, education etc.
Taxation and tax incentives like pioneer status, tax holidays amongst others attract foreign investors to the country. Capital allowances also provides businesses the opportunity to recover the amounts they spend in capital expenditure. This will result in an expanded economy and thus an economic growth.
The role taxation must play in an economy cannot be overstressed. However, this can only be attained when the country crafts and implements a tax policy which is designed to mitigate the identified difficulties in its tax system.
3.1 CHALLENGES OF TAXATION IN NIGERIA
There is no doubt that taxes are the most stable and reliable source of government revenue. However, Nigeria as a developing country is yet to attain full potentials due to the current challenges in the tax system. These challenges include the following:
- Poor Governance: There is a relationship between governance and tax collection. Where the governance is good, tax collection would be high and if otherwise, it impacts negatively on tax generation. In Nigeria, there is a poor accountability for the taxes collected from taxpayers which has resulted in the latter providing the basic services they need themselves. Therefore, they do not see any compelling reason to pay taxes though paying taxes is not a quid pro quo.
- Transparent Tax Administration: The focus of tax administration is more on tax collection rather than helping taxpayers become more compliant. The approach to tax audits and investigations does not reflect healthy scepticism.
- Ineffective Tax Policies: Nigeria has a National Tax Policy that defines the underlying principles of an effective tax system. However, those principles are not consistently adhered to.
- Fragmented Database – There has been significant revenue leakage because there is no alignment of the various databases in the country. Moreover, there is little or no system for the exchange of information among the various tax authorities as they tend to work independently of one another.
- Inadequate Capacity of Tax Authorities: Some tax authorities do not have sufficient capacity to perform their duties and responsibilities. So, tax audits and investigations tend to drag for indefinite months or years.
- Multiple Taxation: This has been a common phenomenon given the desire by the various States to grow their internally generated revenue since allocations given to them has significantly reduced.
There is no doubt that Nigeria is facing a revenue challenge. Maximising the country’s tax potential is, therefore, the way forward. There are challenges in tax administration and policy that we need to address. The sooner we address these issues, the better for the country. It is encouraging that the present administration is fully aware of these issues and has decided to place the reform of the Nigerian tax system on the front burner.
It cannot be over-emphasized, the importance of good governance if the country wants to promote voluntary compliance and grow the tax-to-GDP ratio to 18% by 2025. Tax authorities must cultivate the culture of treating taxpayers as clients and exhibit healthy scepticism when it comes to tax audits and investigations. It is also important that we implement effective anti-corruption measures and internal controls by reducing human intervention in tax administration as much as possible.
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 Reforming Nigeria’s Tax Incentive Program – Adewale Ajayi, Business Day 26 November 2022