Shelze Admin ยท June 2026
VAT Input Claims, Self-Charge Obligations, and the CIT Deductibility Trap Under the Nigeria Tax Act 2025
Many Nigerian businesses are paying more VAT and CIT than the law requires. The session examined the three compliance areas where organisations are most exposed under the NTA 2025: recovering input VAT that has been paid but not claimed, accounting for the self-charge mechanism on imported services, and ensuring that CIT deductions meet the documentation and arm’s-length standards that the NRS is now applying with increasing rigour.
The session also explained how a single missed step in one area can cascade into exposures across all three โ what we called the “double cost” โ where a VAT compliance gap simultaneously eliminates a VAT recovery and puts a CIT deduction at risk.
The full slide deck from the session covering VAT input claims, the self-charge mechanism, and CIT deductibility under the NTA 2025.
31 check items across four areas. A practical tool your finance team can use to assess your VAT input claims, self-charge compliance, and CIT deductibility positions.
Watch the full 75-minute session. Covers VAT input claims, the self-charge mechanism, CIT deductibility, and the VAT–CIT double cost under the NTA 2025.
of poll respondents correctly identified that a missed self-charge creates a cascading exposure across VAT, penalties, lost input claims, and CIT deductibility.
said their organisation has either not conducted a comprehensive review of its NTA 2025 VAT/CIT position, or is not sure whether it has.
do not verify invoices against NTA 2025 requirements before claiming input VAT, or are not sure whether they do โ the most common cause of rejected claims.
Is there a time limit for claiming input VAT that was previously unclaimed?
Under the NTA 2025, input tax incurred by a registered person on any taxable supply can be claimed as a deduction against the tax payable on their taxable supplies within five years after the end of the tax period in which the input tax was incurred. However, if a taxable person is specifically requesting a VAT refund (rather than utilising it as a credit), the request must be submitted to the NRS no later than 12 months after the transaction that gave rise to the refund.
Does the self-charge obligation apply to software licence fees paid to a foreign parent company?
Yes. The NTA 2025 does not make an exemption for intra-group software licence fees. Where a Nigerian company receives a service โ including a software licence โ from a non-resident entity, the self-charge obligation applies. The company must account for VAT as both supplier and recipient.
How does the e-invoicing requirement under the NTA 2025 affect input VAT claims?
The e-invoicing system helps to validate the existence and substance of a transaction. An invoice validated on the e-invoicing system should be straightforward to evidence during an NRS audit. Conversely, input claims supported by invoices that are not on the e-invoicing platform may face additional scrutiny.
What happens to open-market or across-the-counter expenses regarding documentation?
The law does not make an exemption for across-the-counter transactions. The purchaser must ensure that the seller at least has a Tax Identification Number and that it is displayed on the transaction documents. For the VAT component, the buyer can self-charge where the seller is not VAT-registered.
If we discover we have not been self-charging VAT on imported services for the past two years, what is the best way to regularise this with the NRS?
A proactive regularisation is significantly better than waiting for an NRS audit to uncover the gap. The recommended approach is to quantify the total liability (including the corresponding input claims that can be recovered), prepare the supporting documentation, and engage with the NRS through a voluntary disclosure. Our tax team can guide you through this process โ simply reply to the follow-up email or contact us directly.
How can a company recover self-charged VAT when 100% of VAT output has been deducted at source by the customer?
Having your VAT output deducted at source may put you in a VAT refund position if you have claimable input VAT. In that scenario, you can apply for a refund from the NRS. The key is to ensure that the self-charge is properly accounted for so that the corresponding input claim is created.
If any of the issues covered in this session apply to your organisation, our tax team is available for a brief, confidential conversation to help you assess your VAT and CIT compliance position.