Digital Tax Reform and the FIRS–France MoU: Modernisation or Managed Sovereignty?

                                                                                                                                                      Political Panorama Issue No 29

In December 2025, the Federal Inland Revenue Service (FIRS) signed a Memorandum of Understanding with France’s tax authority, the Direction Générale des Finances Publiques (DGFiP), to collaborate on digitalising Nigeria’s tax administration. The agreement arrived just weeks before the formal transition of FIRS into the Nigeria Revenue Service (NRS) on January 1, 2026, under the recently enacted Tax Reform Act.

                   

Federal Inland Revenue Service, Dr Zach Adedeji and French Ambassador to Nigeria, Marc Fonbanstier during the signing ceremony: Credit FIRS
Framed as a capacity-building initiative, the MoU promises improved cross-border cooperation, enhanced data-driven enforcement, and the modernisation of Nigeria’s digital tax systems. Yet behind this hopeful language lie profound questions about sovereignty, data governance, the balance of power in international tax diplomacy, and the protection of Nigerians in a rapidly expanding digital fiscal state.

Political Panorama interrogates the MoU across legal, institutional, technological, fiscal, geopolitical, and democratic dimensions, offering a full-spectrum analysis of the implications for Nigeria.

Legal and Institutional Stakes: Between Reform and Dependency

Digital tax modernisation is essential for broadening the tax base, reducing leakages, and aligning Nigeria with global best practices. Collaboration with a sophisticated tax authority like France’s DGFiP offers clear benefits in terms of technical expertise, administrative standardisation, and exposure to advanced compliance systems.

Yet the legal terrain is fraught with risks. When foreign administrative templates are imported wholesale into domestic governance structures, there is a danger of de facto rule-making by external actors. If software, procedures, or compliance frameworks designed for France are embedded into Nigerian systems without full legislative oversight, Nigeria could inadvertently surrender control over key policy levers.

Moreover, the speed of technological reform can outpace Nigerian statutory frameworks. Where digital tools create new enforcement powers or new categories of taxpayer data, the absence of explicit legal safeguards threatens citizens’ rights and creates governance grey zones. In short, modernisation must occur within Nigerian law and not around it.

Data Governance and the Protection of Nigerians

The shift towards digital tax administration requires extensive collection, processing, and storage of personal and financial data. This makes data governance the single most critical sovereignty issue in the MoU.

The following unanswered questions loom large:

1.     Will Nigerian taxpayer data be transferred to or processed in France?

2.     What controls govern access to, use of, and storage of such data?

3.     Do Nigerians retain full rights under the Nigeria Data Protection Act?

4.     Are there safeguards against surveillance, profiling, or political misuse?

Without explicit, published data-protection clauses, the risk of data colonialism emerges where a foreign state gains privileged access to granular financial information of Nigerian individuals and corporations. Function creep is a further danger. Data collected for tax purposes may be repurposed for law enforcement, immigration, or political control if guardrails are absent.

Algorithmic opacity compounds these risks. If automated tax risk-scoring determines audits or sanctions without clear explanations and appeal mechanisms, taxpayer rights become vulnerable. The protection of Nigerians demands transparent disclosure of the data architecture underlying the partnership.

Technological Architecture, Cybersecurity, and Vendor Dependence

Beyond laws and data, the technical systems themselves shape sovereignty. Foreign-built software, foreign-hosted cloud systems, or foreign-controlled analytics platforms can create long-term dependency. Vendor lock-in is one of the most under-discussed threats. Once a system becomes the backbone of national tax administration, the foreign provider wields structural leverage. Cybersecurity risks multiply when systems are interconnected or outsourced. A breach in any part of the chain exposes Nigerians to identity theft, financial fraud, and blackmail.

To avoid these risks, Nigeria must insist on:

1.     local hosting of core databases

2.     source-code escrow

3.     open standards and interoperability

4.     independent cybersecurity audits

5.     transparent procurement processes

The architecture of a digital tax system is a matter of national security, not mere technical convenience.

Fiscal and Economic Implications: Gains and Growing Pains

Nigeria has one of the lowest tax-to-GDP ratios in Africa. Digitalisation, if done correctly, can significantly increase non-oil revenues without raising statutory rates.

The potential benefits include:

1.     improved enforcement of cross-border digital transactions

2.     reduced profit shifting by multinational corporations

3.     more accurate VAT collection on digital services

4.     broader tax net inclusion

But without careful design, digital tax reform can unintentionally increase compliance burdens on small businesses, gig workers, and informal sector actors, the very groups already grappling with inflation and economic instability. Automated enforcement systems may disproportionately target low-income taxpayers who lack digital literacy or access to professional tax advice. True fiscal reform must strike a balance between revenue generation and social fairness.

Cross-border Enforcement and Extraterritoriality

Cross-border information exchange is crucial for combating tax evasion, but it also creates sovereignty trade-offs.

If the MoU allows France broad access to Nigerian data or facilitates enforcement actions originating in France, Nigeria must ensure:

1.     strict reciprocity

2.     judicial oversight

3.     clear legal limits on data use

4.     transparent reporting of foreign access requests

The risk involves asymmetric cooperation where Nigeria contributes more than it receives, or where foreign authorities gain influence over domestic fiscal decisions. Sovereignty in tax matters is not merely symbolic, but it is about protecting Nigerian citizens and businesses from undue foreign intrusion.

Transparency, Accountability, and Democratic Oversight

The biggest red flag thus far is opacity. Neither the MoU nor its technical annexes have been published. Nigerians do not know the details of the systems being imported, the data being shared, or the oversight structures being created.

In a democracy, secrecy around a major transformation of the fiscal state is unacceptable. Taxation is the most potent instrument of state power. Any reform that increases state visibility into citizens’ financial lives must be subject to robust debate, legislative scrutiny, and public transparency.

Nigeria must avoid the drift toward a technocratic fiscal regime where foreign-designed systems circumvent local democratic institutions.

Capacity Building and Institutional Ownership

At its best, the MoU could build strong Nigerian institutions capable of independently managing advanced digital tax systems. But capacity-building must be genuine, measurable, and tied to clear outcomes.

If training is shallow, technical assistance is externalised, or expatriate experts occupy pivotal roles, Nigeria risks creating a façade of reform while remaining structurally dependent on foreign expertise.

Institutional autonomy is not measured by software installation. It is measured by ownership.

Geopolitics and the Strategic Positioning of Nigeria

France’s global tax diplomacy is strategic. By building deep administrative ties with developing economies, France strengthens its influence within the international tax order, especially the post-BEPS environment where OECD standards shape global norms.

Nigeria must engage strategically, avoiding a partnership that limits future flexibility or binds the country too tightly to a single geopolitical partner.

Digital tax systems are increasingly instruments of global influence. Nigeria must approach such partnerships with both open arms and open eyes.

Conclusion: Modernisation with Caution

The FIRS–DGFiP MoU has immense potential. Nigeria desperately needs a modern, transparent, digital tax system. Cooperation with experienced partners can accelerate progress and enhance fiscal resilience.

But reform without safeguards becomes vulnerability.

And digitalisation without transparency becomes overreach.

Nigeria must pursue digital tax reform as a sovereign nation, not a passive recipient of foreign templates. The government should immediately:

1.     publish the MoU and all data-protection assessments

2.     establish parliamentary oversight committees

3.     mandate data localisation and algorithmic transparency

4.     strengthen citizen appeal rights

5.     ensure local capacity replaces foreign dependency

The success of this partnership will depend not on the technology imported but on the sovereignty preserved, the rights protected, and the institutional capacity built.

Nigeria must modernise but never at the expense of the Nigerian people.

                                 ………………..STOP PRESS……………..

“You Cannot Tax Hunger”: Opposition Slams Tinubu’s New Tax Law, Demands Immediate Suspension

The National Opposition Movement (NOM), at a recent press conference in Abuja, condemned President Bola Tituba’s proposed tax law, describing it as not a reform but a “direct assault on the livelihood of ordinary Nigerians.” The group argued that Nigeria is already facing severe insecurity, poverty, unemployment, and a declining quality of life, and that introducing a punitive tax regime amid subsidy removal, inflation, and the naira's collapse would further impoverish citizens and small businesses.

NOM criticized provisions that require all adults, including the unemployed, to file tax returns, warning that weak institutions, poor internet access, and widespread joblessness would turn the policy into an exploitative enforcement racket. The group accused the administration of prioritizing oligarchic interests over citizens’ welfare, lacking transparency and accountability, and presiding over state capture and grand corruption, including opaque tax-related agreements with foreign entities.

Aligning with organized labor (NLC and TUC) and opposition voices, NOM called for the immediate suspension of the tax plan, nationwide consultations, social protection guarantees, and a shift toward taxing luxury, excess profits, monopolies, and corruption rather than poverty. The movement warned that forcing the tax through without consultation would deepen social and economic crises, stressing that Nigeria’s problem is not low taxation but waste, mismanagement, and policy arrogance.

  Ola Olateju is a political analyst, columnist, and host of Political Panorama, a platform that dissects power, policy, and political behaviour across Africa and beyond. His works focus on governance, leadership ethics, and the moral undercurrents of democracy.

                         A Message of Appreciation from Political Panorama

As the year draws to a close, the entire Political Panorama team extends our heartfelt appreciation to our numerous readers for your unwavering support, thoughtful direct messages, words of encouragement, and constructive comments throughout the year. Your engagement inspires our work and strengthens our commitment to informed, courageous, and people-centered commentary.

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Political Panorama will resume publication on January 15th, 2026.

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Political Panorama with Ola Olateju

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