Regulators, oil and gas executives, and cryptocurrency firms used a corporate tax governance session at the  Festival to call for closer collaboration between governments and businesses, arguing that inconsistent implementation, policy ambiguity, and weak engagement are undermining tax compliance across African markets.

The discussion brought together representatives from the Nigeria Revenue Service, the oil and gas sector, and the digital asset industry, with speakers repeatedly returning to the same theme: Africa’s tax challenges are no longer simply about enforcement, but about clarity, communication, and the ability of regulators to keep pace with rapidly changing industries.

Digital taxation and the crypto challenge

Sebastian Odima, Head of Tax at Yellow Card, said digital taxation policies are often developed without sufficient understanding of how emerging industries operate, particularly within the cryptocurrency sector.

Odima referenced a proposal to impose a three percent charge whenever cryptocurrency is converted into local currency, commonly referred to as an off-ramp transaction. While the proposal was intended to improve tax collection, he argued that the structure failed to account for whether users were making gains or losses on those transactions.

“What if the person has made losses? How is that being addressed?” Odima asked.

“If you don’t have that engagement with policymakers, then instead of supporting corporates that want to comply, you will drive a lot of people into the black market where you are unable to tax anyone.”

According to him, poorly designed tax systems risk discouraging compliance and pushing digital transactions into informal markets that regulators are unable to track effectively.

Odima also highlighted the growing challenge of digital nexus rules across Africa, where companies may face tax obligations in countries where they have no physical office or registered entity. He noted that digital service taxes, significant economic presence rules, and broader tax contribution frameworks are reshaping how governments approach cross-border digital businesses.

“The rules are changing faster than many businesses can adapt,” he said, adding that regulators and policymakers need stronger engagement with industry operators before introducing new frameworks.

Filing versus compliance

Angela Namani, Head of Returns, Payments and Process at the Nigeria Revenue Service Large Tax Office for Midstream Oil and Gas, said many companies continue to approach tax compliance as a filing obligation rather than a governance issue.

According to Namani, filing tax returns on time does not necessarily translate into full compliance, particularly in areas such as VAT reporting and transfer pricing.

“What some companies do is just file their returns and get it done. Submit before the twenty-first of the month. Fulfill all righteousness,” she said.

“But if you look at the law, VAT is a monthly obligation. You are supposed to declare your income, your exempted items, your zero-rated items, claim your inputs. For some companies, it is not like that.”

Namani identified transfer pricing as one of the biggest structural gaps facing tax authorities, particularly where multinational companies shift profits through intercompany charges, royalty payments, service fees, and related-party loans into lower-tax jurisdictions.

She said companies with stronger tax governance systems typically integrate tax considerations into business decisions from the beginning, rather than treating compliance as a process that starts after transactions have already taken place.

Her comments reflected a broader argument raised throughout the session — that weak tax governance often stems less from an absence of laws and more from gaps in internal systems, communication, and enforcement consistency.

Managing regulatory complexity

Adebola Thomas, Head of Tax at First Exploration & Petroleum Development Company, said companies operating in highly regulated industries such as oil and gas must now navigate overlapping layers of legal, fiscal, and operational complexity.

“Tax is complex enough. The oil and gas industry is also a complex industry,” Thomas said.

“It is like complexity raised to the power of two. But with the right governance in place, those complexities are simplified.”

Thomas pointed to the pace of regulatory change within Nigeria’s energy sector in recent years, including the Petroleum Industry Act, successive Finance Bills, and broader tax reforms, arguing that companies with stronger governance structures are generally better positioned to adapt to policy shifts.

“A good tax governance will always be future-ready,” he said.

“Even if you don’t understand everything at the moment, you would have processes and policies in place so that when changes happen, you know what to do.”

The case for co-creating tax policy

One of the strongest areas of agreement during the session centered on the need for earlier engagement between regulators and businesses during policy development.

Thomas argued that tax frameworks are often designed without sufficient industry participation, leading to regulations that become difficult to implement effectively once introduced.

“The tax law is conceived by a different person, written by another person, enforced by a totally different person, and affects another person entirely,” he said.

“Regulations that are co-created have a better impact. When you co-create, everybody owns it.”

Namani largely agreed with that position, noting that stronger communication between regulators and the private sector can improve both compliance outcomes and enforcement efficiency.

Panelists also stressed the importance of regulatory certainty, particularly for businesses operating across multiple African jurisdictions where tax rules may vary significantly or change frequently.

Why certainty matters

Odima cited the revised withholding tax framework as an example of how greater clarity can reduce disputes during audits and improve compliance behaviour among corporates.

“Before, whenever NRS came for an audit, no matter how good your compliance people are, your withholding tax liability was always there,” he said.

“Because someone would say, ‘I don’t agree it should be five percent.’ That kind of thing does not encourage compliance.”

Despite representing different sides of the tax system, the panelists ultimately converged around a similar conclusion: improving corporate tax governance across Africa will require more than stronger enforcement measures.

Instead, they argued that sustainable compliance depends on clearer laws, earlier engagement between regulators and businesses, stronger governance systems within companies, and tax frameworks that reflect the realities of increasingly digital and cross-border economies.