The state cannot tax through illegitimacy

A government cannot threaten lawful businesses with penalties for missing tax deadlines while ignoring troubling questions about the legality of those appointed to enforce the same rules.

This is not merely an administrative contradiction. It is moral, legal, and deeply political. It strikes at the foundation of trust, and trust is the first currency any serious tax reform must earn before it touches a single kobo.

The controversy surrounding the appointment of Executive Directors of the Nigeria Revenue Service now moves far beyond routine politics. By law, each geopolitical zone should be represented alphabetically in appointments. Only the South South appears to have complied. The rest have flouted the statutory sequence.

This is where the danger begins. Tax administration is not just about raising revenue. It is about moral authority. Citizens comply most willingly when they trust both the law and those enforcing it. When leadership arrives in office under a cloud of statutory doubt, every demand it makes begins to lose force.

The question is no longer merely whether taxpayers must meet deadlines. The deeper question is whether those supervising compliance are themselves products of lawful discipline. For the Nigeria Revenue Service, this is an especially perilous starting point. A revenue institution survives on trust as much as statutes. Once perception hardens that leadership may have bypassed legal requirements, credibility erodes faster than any compliance portal can operate. Every notice sent to a company, every audit request, every penalty warning will now be read against a larger question. Is this a system built on law or on convenience?

The law itself remains valid. The Nigeria Revenue Service Establishment Act 2025 is not rendered void. But institutions do not survive on legality alone. They survive on public confidence that the hands enforcing the rules themselves obeyed them. This is the true burden of legitimacy.

If the North Central slot, for example, was supposed to go to Benue State but was instead assigned to Niger State, this is no longer a regional grievance. It becomes a test of whether Nigeria’s fiscal reform begins with fidelity to law or with the old culture of executive convenience. Similar discrepancies across other zones reinforce the perception of arbitrariness.

This precedent is dangerous. A tax regime that appears selective in its own obedience weakens the ethical foundation upon which voluntary compliance is built. Businesses do not merely pay taxes because the law threatens them. They comply because the state demonstrates competence, predictability, and legal seriousness. The moment the enforcer seems born of procedural ambiguity, compliance becomes defensive. Trust gives way to suspicion. Cooperation becomes grudging. Moral authority decays from the top downward. That is how reform fails before its first real test. Framers and defenders of the new fiscal order must confront this contradiction directly. A reform is judged not only by the brilliance of its drafting but by the integrity of its implementation. If the institution meant to embody reform begins under a shadow of controversial appointments, silence from architects may be read as consent. And consent in moments of institutional illegitimacy is reputationally expensive.

There is something corrosive about a state demanding precision from businesses while appearing lax about precision in its own appointments. The rule of law loses meaning the moment it stops being symmetrical. Government cannot demand obedience downward while practicing ambiguity upward.

For businesses, this is not an abstract debate. It affects confidence, planning, and willingness to engage openly with the tax system. Investors and employers need certainty that those assessing liabilities and enforcing penalties sit in office by law and competence, not political convenience. Anything less breeds hesitation. Anything less weakens reform. Anything less turns what should have been a trust-based fiscal renaissance into reluctant compliance, grudging compliance, or outright resistance.

This moment is bigger than who gets appointed. It is about whether Nigeria’s new tax order wants to stand on trust or intimidation. The law cannot demand obedience from citizens while excusing its own enforcers. If reform is to endure, it cannot begin with the old habit of rewarding power with exceptions while demanding discipline from everyone else.

The law must first cleanse the hands that enforce it, because no nation builds lasting compliance on a foundation of institutional hypocrisy.

The state cannot tax through illegitimacy. Unless this contradiction is corrected at the top, every kobo demanded below will carry the weight of a deeper national question: who first obeyed the law that now seeks to govern everyone else?