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Recalibrating Nigeria’s tax-based incentive regime: From PSI to EDTI

Since independence, Nigeria has launched a spread of insurance policies and legal guidelines to outline its industrialisation aspirations.

Extra just lately, the Federal Authorities has articulated an ambition of positioning the nation among the many world’s high 20 industrialised economies and reaching a one-trillion-dollar GDP.

To grasp this imaginative and prescient, successive reforms have sought to remodel Nigeria from a mono-product, import-dependent financial system right into a aggressive contributor to international worth chains.

Probably the most consequential of those reforms is the overhaul of the tax administration framework, culminating within the enactment of the Nigeria Tax Act (NTA) 2025, a landmark laws consolidating the nation’s disparate tax legal guidelines.

Complementing that is the Nigeria Income Service Act, 2025, which offers a extra coherent administrative framework for tax assortment and administration.

A principal element of this reform is the substitute of the Pioneer Standing Incentive (PSI), beforehand ruled by the Industrial Growth (Earnings Tax Reduction) Act (IDITRA), with the brand new Financial Growth Tax Incentive (EDTI) below Sections 166–183 of the NTA 2025.

IDITRA is repealed with impact from January 1, 2026. This transition represents way over a authorized replace; it’s a strategic recalibration of Nigeria’s funding incentive regime.

Whereas each PSI and EDTI, administered by the Nigerian Funding Promotion Fee (NIPC), share the overarching aim of stimulating funding in sectors essential to industrial and financial improvement, their frameworks diverge sharply in design, scope, and accountability.

The Pioneer Standing Incentive (PSI): Strengths and Limitations

Underneath IDITRA/PSI, corporations designated as “pioneer” loved a tax vacation exempting them from Corporations Earnings Tax (CIT) for 3 years, extendable by two extra years. Crucially, PSI was not open-ended; it utilized solely to qualifying industries and actions listed on the Pioneer Record.

Though IDITRA didn’t mandate biennial updates of the checklist, in apply, the NIPC, topic to the approval of the Honourable Minister of Business, Commerce and Funding (FMITI), reviewed and up to date it each two years by way of publication within the Federal Gazette.

Purposes have been required inside the first yr of manufacturing, and NIPC utilized administrative thresholds to confirm funding/Qualifying Capital Expenditure (QCE) upfront below minister-approved pointers.

The historic weak spot, nevertheless, lay in after-grant monitoring. Reporting and efficiency assessments weren’t persistently enforced, which meant some companies retained advantages with out assembly clear post-approval obligations. Because of this, questions endured about whether or not PSI persistently delivered on its promise of stimulating sustainable, broad-based industrial improvement.

The Financial Growth Tax Incentive (EDTI): A New Paradigm

Against this, the EDTI below the NTA 2025 introduces a performance-based system that strikes away from tax holidays. As a substitute of exemptions, eligible corporations will now obtain tax credit equal to five% of their Qualifying Capital Expenditure (QCE), granted yearly for 5 years. Unused credit may be carried ahead, with a potential extension of as much as ten years, the place earnings are absolutely reinvested.

In contrast to the administratively guided thresholds of PSI, QCE thresholds are actually codified in regulation, usually starting from ₦250 million to ₦200 billion by sector. Protection is explicitly outlined within the Tenth Schedule, encompassing precedence areas comparable to manufacturing, agriculture, mining, renewables, and ICT.

The shift additionally redefines the position of the NIPC. The Fee strikes from being primarily a process-stage administrator to turning into a regulatory enforcer. It should now:

  • guarantee purposes are filed earlier than manufacturing commences (which had all the time been in operation),
  • implement strict QCE certification,
  • conduct unbiased post-approval audits, and
  • monitor compliance with stronger anti-abuse guidelines and detailed submitting obligations.

Importantly, EDTI prohibits companies from combining the inducement with different tax holidays (e.g., Free Zone exemptions), a loophole beforehand managed solely by way of administrative guidelines below PSI.

Why EDTI Issues

In abstract, whereas each PSI and EDTI share development-driven goals, the EDTI represents a deliberate shift to a rules-based, clear, and performance-driven regime. By embedding sector-specific thresholds into statute and introducing enforceable compliance mechanisms, the EDTI strengthens accountability and reduces administrative discretion.

This recalibration ensures that solely real, growth-aligned investments profit from incentives, whereas positioning the NIPC as an enforcer of compliance moderately than merely a facilitator of approvals. Finally, the EDTI displays Nigeria’s broader dedication to institutionalising accountability, enhancing enterprise setting governance, and aligning incentives with measurable financial improvement outcomes.

Comparability Desk

Introduced beneath is an analytical evaluation contrasting the Pioneer Standing Incentive (PSI) with the brand new Financial Growth Tax Incentive (EDTI). The evaluation underscores how the EDTI establishes a extra clear, rules-based, and performance-driven framework—designed not solely to draw funding, but additionally to make sure that such investments ship measurable and sustainable outcomes that strengthen and drive Nigeria’s industrial and financial improvement.

 

Conclusion

This evaluation has offered an unbiased evaluation of the PSI regime and its transition to the EDTI. The evaluation highlights the structural and coverage shifts launched by the brand new framework, notably in strengthening transparency, compliance, and funding accountability. Whereas it doesn’t make evaluative judgments on the NIPC’s administration of the PSI, it underscores how EDTI displays Nigeria’s broader effort to institutionalise accountability and align funding incentives with measurable financial improvement outcomes. Total, it contributes to understanding the evolution between each regimes as a part of the federal government’s spirited effort to reinforce enterprise setting governance, strengthen competitiveness, and embed sustainability imperatives.

 

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