There is a pervasive fear among Nigerians—often fueled by aggressive headlines—that the government is on the verge of peering into your bank account and arbitrarily debiting “unpaid taxes” based on your daily transaction alerts.

The fear is understandable. The government is desperate for revenue. The recent passage of the Income Tax Act (ITA) 2025, a product of the current administration’s tax reform committee, was meant to modernize our archaic tax laws. Despite the fanfare, the new Act has failed to address the fundamental structural flaws in the old Personal Income Tax Act (PITA).

Here is the cold, hard reality: The Nigerian government cannot—and will not—tax your bank account directly anytime soon. Here is why.

The Wrong Taxman has the Data (Federal vs. State)

The primary safeguard preventing Nigeria from taxing your personal bank account is Nigeria’s federal structure.

Under the Nigerian constitution and retained by the ITA 2025, the Federal Government (via the FIRS or the newly proposed Nigeria Revenue Service) collects taxes from companies. The State Governments (via their State Internal Revenue Services) collect taxes from individuals.

This creates a massive disconnect. The Federal Government has the data. Through the NIBSS and BVN frameworks, the Federal Government can theoretically track money flows.  However, the Federal Government cannot legally collect Personal Income Tax (PIT) from you unless you are a police officer, military personnel, or a diplomat. For the remaining 99% of the population, that right belongs to the state where you reside.

The FIRS cannot simply hand over your banking data to 36 states because of complex data privacy and banking secrecy laws that remain largely unaddressed by the new Act. A simple fix such as enacting a nominal federal income tax (say 1%) would have significantly enabled the sharing of data between Federal and State Tax agencies. It could also be used as tool to transfer funds to the vulnerable rather than the current opaque method done via the Ministry of Humanitarian Affairs.

The 35 Weak Links (State Internal Revenue Services)

If you live in Lagos, you might have reason to be slightly worried. The Lagos State Internal Revenue Service (LIRS) is an outlier—technologically advanced and aggressive. But for the rest of the country? The system is broken.

Aside from Lagos and perhaps the FCT, most State Internal Revenue Services (SIRS) are hollow institutions. They are often headed by political appointees—friends of the Governor with zero depth in tax administration or forensic accounting.

These agencies lack the software to analyze bank statements even if they had them. They lack the political will to compel their wealthy residents to pay the right amount of tax because these wealthy individuals may very well be the sponsors of those holding the highest political positions.

The State IRS rely almost exclusively on Pay-As-You-Earn (PAYE), where companies do the work for them by deducting taxes at the source. They lack the capacity to audit the millions of personal bank accounts within their domain. They are too weak to enforce collection on individuals who do not earn a salary.

The “Secondee” Loophole

The most glaring weakness of the ITA 2025 is that it was touted as a reform to capture the wealthy, yet it arguably makes it easier for the ultra-rich to slip away.

A major flaw exists in the definition of taxable income regarding “Secondees”—expatriates or Nigerians seconded from foreign firms to work in Nigeria. The Act appears to completely exempt the income of a secondee if they can prove they are paying taxes in their “home country.”

This is a massive oversight. It means a high-earning executive earning $20,000 a month in Nigeria can avoid paying any tax to the Nigerian state by presenting a tax receipt from a low-tax jurisdiction or their home country. While the average Nigerian employee has their tax deducted at source, the high-net-worth individual with complex global income sources is given a legal exit route. If the law cannot even capture the clearly defined income of a corporate executive, it certainly lacks the sophistication to scrutinize the murky inflows of a personal savings account.

Bank Turnover ≠ Taxable Income

Finally, there is a legal hurdle that the tax authorities have not cleared. A credit alert in your bank account is not proof of income. If your spouse transfers money to you for school fees, that is not income. If you sell a used car and the buyer transfers cash, that is a return of capital, not necessarily profit. If you receive a refund for a failed transaction, that is not income.

For a tax authority to tax your bank account, it must first distinguish between revenue and income. This requires a level of forensic auditing that simply does not exist at the state level. They cannot simply apply a flat tax rate to your total credit alerts without facing lawsuits they would almost certainly lose in a working judiciary.

Conclusion

While ITA 2025 has rearranged the furniture, the house remains the same. As long as the collection of personal income tax is left to 36 disparate, under-resourced, and politically compromised State Boards, your bank account remains relatively safe.  And as long as every Nigerian does not pay personal income tax to the center, the current tax reforms from a personal income perspective are inchoate.

The taxman may bark, but until the constitution is amended to centralize personal tax collection—or until the States wake up and employ technocrats rather than politicians—he has no teeth to bite your savings.

Eben Joels is the Managing Partner of Stransact Chartered Accountants, an audit, tax, and consulting firm in Nigeria. He is also a subject-matter expert in International Tax and Financial Reporting Standards and a licensed attorney.