TRANSITION FROM THE FEDERAL INLAND REVENUE SERVICE TO THE NIGERIA REVENUE SERVICE: LEGAL ISSUES ARISING

Abstract

Beyond every infinitesimal vestige of doubt, the repeal of the Federal Inland Revenue Service (Establishment) Act and its replacement by the Nigeria Revenue Service (Establishment) Act 2025 represents a reshaping of Nigeria’s fiscal and administrative laws. The problem stems from the legal, institutional, and operational complexities during the transition from the old regime, which is repealed, to the new regime which has come into existence, as well as with respect to continuity of rights, liabilities, and pending litigation. This article critically considers sections 40 and 41 of the 2025 Act as they relate to repeal, savings, and transitional provisions. This allows for the determination of weaknesses and discrepancies that could undermine the stability or legitimacy of revenue administration during this transitional period. Methodology-wise, the article deploys a doctrinal form of legal analysis by way of statutory interpretation, comparative assessment, and analogical reasoning in order to situate the change in Nigeria’s administrative law. The central argument is that the 2025 Act secures institutional stability of fiscal governance, which implies the need for clearer judicial guidance in pronouncements concerning administrative disputes. The article finds that the repeal is defensible substantively, but there is a need for administrative convergence and interpretative consistency.