A company opens a bank account, and the bank asks for its tax identification number. It wins a contract, and the client asks for the number on the invoice. It applies for a tax clearance certificate and finds that the number has not been validated, so the online application cannot start.
The TIN is the key that opens almost every other tax process, which is why registration comes first in the course.
This topic covers what the TIN is and where it must appear, the duty of banks, the time limits for registering, the letters and documents for income tax and VAT, the registration of individuals, sole proprietors and employers, validation and the e-service, and the registration of non-resident companies. The previous topic covered the national tax policy. The next covers returns, assessments and payment.
In 30 seconds
TIN (section 10, CITA, Finance Act 2019): every company has one and displays it on all business transactions, documents, statements, returns, audited accounts and letters to revenue bodies; banks require it to open or keep an account (existing accounts within three months of the Act).
Companies register: with FIRS within 18 months of incorporation or six months after the end of the first accounting period, whichever is earlier; VAT within six months of commencing business. Two letters: one for income tax, one for VAT. Individuals: register with the state authority within three months. Employers register as agents for PAYE. E-service: register online, validate the TIN at the local office, then file online.
Key terms in plain English
| Term | What it means |
|---|---|
| TIN | Tax identification number issued to each taxable person |
| Registration letter | A written application to the revenue to register for a tax |
| CAC 2 | The CAC form on the allotment of shares |
| CAC 7 | The CAC form on particulars of directors |
| VAT Form 001 | The VAT registration form |
| Validation | Confirming the TIN at the local tax office for online use |
Syllabus check
This topic is in syllabus area B, tax administration. It covers:
- the TIN and its use on documents
- time limits and documents for registration
- individuals, employers and non-residents
CAMA 2020 and tax registration
The Companies and Allied Matters Act 2020 (CAMA 2020) is the company law of Nigeria. The sections below apply to this topic.
| Section | What it says | Link to this topic |
|---|---|---|
| s. 377(1) and s. 378 | Directors prepare financial statements that give a true and fair view | The audited accounts that a newly registered company files carry its tax number |
| s. 305 and s. 308 | Directors must act in good faith and with the care, diligence and skill of a prudent director | Directors answer for registering for tax and VAT on time |
| s. 119 | A company must keep proper books of account | The registration papers and tax number are part of the company records |
The rules in more depth
The TIN and where it must appear
Section 10(1) of the Companies Income Tax Act, as inserted by the Finance Act 2019, says every company shall have a tax identification number, to be shown on all business transactions with other companies and individuals and on every document, statement, return, audited account and letter sent to the revenue authorities, including the Federal Inland Revenue Service, ministries and all government agencies.
Section 10(2) says a person in banking or other financial services shall require every company to provide its TIN as a condition of opening an account; for an account already open, the bank was to require the TIN within three months of the Act, as a condition for continued operation.
Who registers with whom
| Taxpayer | Register with |
|---|---|
| An incorporated company | The Federal Inland Revenue Service |
| An unincorporated entity, an individual or a body of individuals | The relevant tax authority of the state where resident |
| An individual or enterprise in the FCT | The FCT Internal Revenue Service |
| An employer | As an agent of the state authority, to deduct PAYE |
| A company with staff and suppliers in several states | Also with the authorities of those states for PAYE and withholding tax |
Time limits
- Income tax: a newly incorporated company writes to the FIRS within 18 months of incorporation or six months after the end of its first accounting period, whichever is earlier.
- VAT: within six months of commencing business (section 8 of the VAT Act).
- Individuals: a taxable person registers with the relevant authority within three months by completing the prescribed form.
The income tax registration letter
The letter gives the company name, registered office, business address, nature of business, date of commencement, bankers and major shareholders. For a company that has not started, it says so and promises to notify the FIRS when it does. With the letter go the certificate of incorporation, the memorandum and articles, Form CAC 2 (allotment of shares) and Form CAC 7 (particulars of directors).
Some versions of the procedure also ask for the adopted year end, the names and addresses of shareholders and directors, the appointed auditor and tax consultants, and certified true copies of the documents. The FIRS registers the company if it is satisfied, and otherwise asks for more information.
The VAT registration letter
A second letter, with a completed VAT Form 001 and the certificate of incorporation. A company therefore sends two letters, one for income tax and one for VAT, usually at the same time.
Electronic registration and validation
With the e-service, registration and filing are done online. After the TIN is issued, the company validates it at its local FIRS office so that it can transact with the Service electronically, and only then can it apply on the portal for a tax clearance certificate. A company that has not validated its TIN cannot start the online process.
Non-resident companies
A non-resident company that is taxable in Nigeria files a return for the year with its full audited financial statements and those of its Nigerian operations authenticated by an independent qualified accountant in Nigeria, schedules of tax computation on its Nigerian profit, a written statement of profit from each source in Nigeria, and the completed self-assessment forms.
If the only Nigerian income is income on which withholding tax is the final tax, it need not file.
Sole proprietors and individuals
A sole proprietor is an individual for tax and registers with the state authority where he lives, within three months, using the prescribed form. A business also pays the state’s business premises registration fee (the maximum fees are ₦10,000 maximum for registration and ₦5,000 for renewal in urban areas, and ₦2,000 and ₦1,000 in rural areas).
An employee has no duty to register separately, because his employer deducts PAYE, but a person with other income needs a TIN to file.
The position from 2026
The Nigeria Tax Administration Act 2025 keeps the tax identification number, and the Nigeria Revenue Service has replaced the Federal Inland Revenue Service. Since 30 April 2026 registration is done on the Rev360 platform, which replaced TaxProMax. The Act also penalises a person who awards a contract to an individual or entity that is not registered for tax, with a penalty of ₦5 million. Use the time limits above for periods before 2026.
Worked examples
Example 1: the date to register for income tax. A company was incorporated on 1 March 2023 and its first accounting period ended on 31 December 2023.
- 18 months from incorporation = 1 September 2024.
- Six months after the end of the first accounting period = 30 June 2024.
- The earlier date is 30 June 2024.
Example 2: the date to register for VAT. The same company started trading on 1 July 2023.
- Six months after commencement = 31 December 2023.
Example 3: a bank and an old account. A bank has a company customer without a TIN when the Finance Act 2019 was passed.
- The bank had to require the TIN within three months of the Act.
- The company could not continue to operate the account unless it provided it.
Example 4: a missing TIN on an invoice. A company sends an invoice that does not show its TIN.
- Section 10(1) requires the TIN on every business transaction and document, so the invoice does not comply.
How to score full marks
- Quote sections 10(1) and 10(2) in two sentences.
- Give both time limits for the company, and say “whichever is earlier”.
- List the documents for each letter.
- State the e-service steps in order.
Common mistakes in the exam
- Giving six months for income tax without the 18-month alternative.
- Giving 18 months for VAT.
- Leaving out Forms CAC 2 and CAC 7.
- Forgetting that banks must ask for the TIN.
Quick revision
- TIN on all documents; banks ask for it.
- Income tax: 18 months or six months after first year end, earlier; VAT: six months.
- Two letters; CAC 2, CAC 7, VAT Form 001.
Practice questions
Questions 1 to 10 are multiple choice. Questions 11 to 13 are written. Try each before opening the answer.
Question 1. Section 10 of CITA requires every company to have a:
- Bank account only
- Tax identification number
- Licence
- Pension number
Show the answer
B. TIN.
Question 2. A bank must require a company’s TIN:
- After a year
- As a condition for opening an account
- Never
- Only for loans
Show the answer
B. Section 10(2).
Question 3. A company registers for VAT within:
- 3 months
- 6 months of commencement
- 12 months
- 18 months
Show the answer
B. Section 8, VAT Act.
Question 4. For income tax, a company registers within:
- 3 months
- 18 months of incorporation or six months after the first year end, whichever is earlier
- 24 months
- 36 months
Show the answer
B. The earlier of the two.
Question 5. Which form carries particulars of directors?
- CAC 2
- CAC 7
- VAT 001
- IR3C
Show the answer
B. Form CAC 7.
Question 6. Which form is the VAT registration form?
- VAT 001
- CAC 7
- CAC 2
- H1
Show the answer
A. VAT Form 001.
Question 7. An individual registers with:
- The FIRS
- The relevant state authority
- The CAC
- The Customs
Show the answer
B. The state of residence.
Question 8. An individual registers within:
- One month
- Three months
- Six months
- Two years
Show the answer
B. Three months.
Question 9. After the TIN is issued, a company must:
- Validate it at the local office
- Do nothing
- Surrender it
- Change it yearly
Show the answer
A. Validation enables online filing.
Question 10. A non-resident whose only income is final-tax withholding income:
- Must file a full return
- Need not file
- Pays double
- Is exempt from VAT
Show the answer
B. No return is needed.
Question 11 (10 marks). State the provisions of section 10 of CITA on the tax identification number. (6 marks)
Question 12 (10 marks). Explain the registration process for a new company with the FIRS, giving the documents required. (10 marks)
Question 13 (10 marks). A company was incorporated on 1 June 2022 and its first accounting year ended on 31 March 2023. State the date by which it must register for income tax. (4 marks)
Model answers
Show the model answer to Question 11
Every company must have a TIN. (1) It must display it on all business transactions with companies and individuals and on every document, statement, return, audited account and letter to revenue authorities. (2) Banks must require it as a condition for opening an account, and for existing accounts within three months of the Finance Act 2019 for continued operation. (3)
Show the model answer to Question 12
Write a letter to the FIRS for income tax and a second for VAT. (2) The income tax letter gives name, registered office, business address, nature of business, date of commencement, bankers and major shareholders. (3) Attach the certificate of incorporation, memorandum and articles, Form CAC 2 and Form CAC 7. (2) The VAT letter has VAT Form 001 and the certificate of incorporation. (2) Validate the TIN at the local office for e-service. (1)
Show the model answer to Question 13
18 months from 1 June 2022 = 1 December 2023. (1) Six months after 31 March 2023 = 30 September 2023. (2) Whichever is earlier: 30 September 2023. (1)
Pathfinder on Tax identification number and registration: who, when and how
These are the ICAN Pathfinder questions that test this topic. ICAN owns the questions and the suggested solutions, so we point you to them and do not copy them. Open your Pathfinder, attempt each question under exam conditions, then check your answer against the notes above.
Revise first: The TIN and where it must appear
Source: ICAN Pathfinder, Taxation. Diets covered: May 2026 and November 2025.
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