Summary
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Nigeria’s Federal Ministry of Finance has invited professional bodies, industry associations, businesses and other stakeholders to comment on a proposed VAT Modification Order 2026. According to the supplied notice, the proposal is intended to clarify VAT exemptions and add Harmonized System codes to Part IV of the Nigeria Tax Act 2025.
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Submissions must identify the contributor, contact details, sector and location, and set out each issue, the justification for change, proposed drafting and expected impact. The stated deadline is 5:00 p.m. on 4 September 2026, leaving affected sectors with a short period to prepare evidence-based representations.
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Importers and businesses supplying potentially exempt goods should assess whether existing or proposed HS-code descriptions align with their products. Misalignment between commercial descriptions, customs classification and VAT schedules can affect pricing, import VAT, recoverability, system configuration and the practical availability of an intended exemption.
Article
Nigeria’s Federal Ministry of Finance has launched a stakeholder consultation on a proposed VAT Modification Order 2026. According to the supplied notice, the draft order is intended to clarify VAT exemptions and introduce Harmonized System codes into Part IV of the Nigeria Tax Act 2025.
The use of HS codes is commercially significant because a VAT exemption expressed through tariff classifications can produce different results from an exemption based only on narrative product descriptions. Businesses may therefore need to determine not only whether their goods fall within an intended policy category, but also whether the relevant customs classification is expressly covered by the proposed schedule.
The Ministry has invited memoranda from professional bodies, industry groups, businesses and other interested parties. Each submission should identify the contributor or organisation, a contact person, email and telephone details, sector or industry, and state or location. For every requested modification, the memorandum should explain the issue, provide justification, suggest draft wording and describe the expected impact.
The supplied notice sets a deadline of 5:00 p.m. on 4 September 2026. Submissions may reportedly be sent to [email protected] or delivered in hard copy to the Director, Technical Services, Federal Ministry of Finance Headquarters, Abuja. The measure remains a consultation rather than enacted law, and businesses should not apply proposed exemptions or classifications until the final order and its commencement provisions are confirmed.
Potentially affected organisations should compare the draft categories with their current product master data and customs-classification database. Particular attention should be given to products for which the same commercial description may fall under different tariff headings depending on composition, technical specifications, function or packaging.
A useful submission should explain the operational consequence of the proposed drafting. This might include unintended taxation of essential inputs, inconsistent treatment at importation and domestic sale, classification disputes, system complexity or market distortions. Quantitative information on transaction values, affected supply chains and consumer-price effects may strengthen the commercial case for amendment.
Tax, customs, legal, supply-chain and product specialists should coordinate their positions. Any recommended HS code should be technically validated before submission, as an incorrect code could narrow an exemption or extend it beyond the intended goods.
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