The data for this study would be obtained from primary and secondary sources. The primary sources include experience and observation. The personal observation techniques involves watching people. Events especially toward tax payment in order to obtained first hand information for the purpose of this research. The secondary source includes the use of textbooks, journals, magazines, report, unpublished thesis periodical etc. the method of analysis to be adopted in his work shall be by the use of simple statistic. Relevant information that depicts the tax structure and characteristics of Nigeria shall be elected from different publication of the federal office of statistics, federal Inland Revenue Service (FIRS) State Board of internal Revenue and shall be presented using percentage, ratios and table in order to have a better picture of taxation in Nigeria. this will make the analysis of the data, clearer and concise.   

            For taxation to be effective and efficient, and for taxpayer to respect the system, there must be proper administration of tax. Tax administration involves the care and management of the phenomenon of taxation. Under the current law in Nigeria, taxation is enforced by three tiers of government i.e Federal, State, and Local Government with each having its sphere clearly spelt out. Section 1 (1) of the taxes and levies (Approved) list for collection Act1 provides that;
Notwithstanding anything contained…in any other enactment of law, the federal government, state government and local government shall be responsible for collecting the taxes and levies listed in part i, part ii, part iii, of the schedule to this Act respectively.

            The companies Income Tax Act, 1990 established the Federal Board of Inland Revenue together with its operational arm called Federal Income Revenue Services (FIRS). It has responsibility to administer companies Incomes Tax Act, petroleum profit Tax Act, and Value added Tax. In addition, FIRS also administers the personal Income Tax Act in respect of residents of the federal capital territory,
members of Nigeria police force, members of Armed Forces  of Nigeria as well as staff of Ministry of Foreign Affairs and non-residents. Furthermore, FIRS has responsibility for the capital Gains Tax Act and Stamp duty at in respect of the resident of the Federal capital territory, corporate bodies and non-residents.
            At the state level, the personal Income Tax Act, 1993 established the State Board of Internal Revenue (SBIR) which responsibility is for personal income taxes of individual and non corporate bodies except resident of the Federal capital territory, members of Armed forces of Nigeria as well as staff of Ministry of foreign affairs and non-residents. In additional it has responsibilities for capital Gains Tax Act and stamp duty Act except those aspects relating to residents of the federal capital Territory, corporate bodies and non-residents.
            The foregoing had been the situation until towards the end of the last regime when the country embarked on a world bank inspired economic reform agenda. This led to the Federal Inland Revenue Services (establishment) Act 2007 thereinafter referred as the Act)2 on tax administration at the state level in Nigeria. The Act was signed into law on 16th April, 2007. The Act created the Federal inland Revenue services (FIRS) and, by virtue of its sections 2, 25 and 68, effectively put under it’s administration, the personal Income Tax Act No. 104, 11993 (PITA) and other tax laws. The said Sections 2, 25 and 68 are to the effect that the FIRS has henceforth taken over the control and administration of taxes and laws specified in seven legislations listed in the first schedule to the Act among others. The legislation are:
1.         Companies Income Tax Act 1990
2.         Petroleum profit Tax Act 1990
3.         Personal Income Tax Act 1993
4.         Capital Gains Tax Act 1990
5.         Value added Tax Act 1993
6.         Stamp duty Act 1990 and
7.         Taxes and levies (approved list for collection) Act 1998
            A study of the above list leaves no one in doubt as to the intention of the Act, which is nothing but a notification of Tax administration in Nigeria albeit though the backdoor. The Act3 has completely wiped out the division of tax administrative responsibilities that hitherto existed between the FIRS and the SBIR. Unlike the previous tax legislations that clearly specified responsibilities of the FIRS or the SBIR as the case maybe, the new Act does not even recognize the existence of the SBIR as a revenue collection agency let alone of identifying where they belong in tax administration under the new dispensation.4 The Act only recognizes the SBIR in section 8(q) as if they are clerical outfits only created to assist the FIRS in issuing taxpayer identification number to every taxable person in Nigeria. In fact section 8 of the federal Income revenue Service (establishment) Act, 2007, list among its functions of the SBIR as provided in the PITA as if the SBIR are already extinct. Given the fact that the SBIR were created by the PITA, the enactment of the Act seriously calls into question the continuous relevance of the SBIR if not their legitimacy.
            A quick glance at the Act will effortlessly reveal that its main objectives are to pave way for the FIRS to take over the functions of the   SBIR.  It   sought  to do  this  by  introducing  a  centralized  tax
administration as being canvassed in the dying days of the fifth republic. That could have been the only reasons why an act meant to create a federal tax agency would contain many provisions that are meant to take over the basic functions of state revenue agencies and make them redundant. For example, sections 26, 27 and 28 o the Act practically plagiarize section 46,47 and 48 of the PITA by empowering the FIRS to call for returns, books, documents and information from taxable individuals preparatory to assessing them for income tax.
            In addition to the forgoing duplication of function of the SBIR by the FIRS,  section 28 (1) of the Act5 went further by compelling Banks to deliver return to the FIRS in respect of taxable individuals under section 48 of PITA are not as wide as those given to FIRS by the Act. In order to further rub it from the SBIR that there is no place for them in the current dispensation, section 59 of the Act empowers the Minister of Finance to establish a Tax appeal Tribunal. The Act specifically extends the tribunal’s jurisdiction under section 1191) of the fifth schedule to cover disputes and controversies arising form the personal Income Tax Act, 1993 and other tax laws. This is an effective way of transforming the Federal Minister of Finance.
            The inclusion of the taxes and levies (approved list for collection) Act, 1998 in the list of legislations to be controlled by FIRS has as its main objectives of this particular legislation to eliminate multiple taxations by specifying the relevant tax authority that can collect specified types of taxes and levies. This is not a tax law per se; rather, it is a law that only identifies tax collection responsibilities among different revenue collecting agencies taking into consideration the federal nature of the country.
            It is pertinent at this stage, to note that Section 4 of the 1999 Constitution as amended (items 58 and 59 of the part 1 of the 2nd schedule) makes impositions of stamp duties and taxations of incomes, profits and capital gains exclusively preserved for the Federal Government. However, item 7 of part 2 of the 2nd schedule to section 4 of 1999 constitution as amended (concurrent legislative list) states that:
In the exercise of its power to impose any tax or duty on:
1.                                          Capital Gains, incomes or profits of persons other                               than companies; and
2.                                          Documents or transactions by way of stamp duties,                              the National Assembly may subject to such                                            conditions as it may prescribe, provides that the                               collection of any such tax or duty or the                                                             administration of the law imposing it, shall be                                       carried out by government of the state or other                           authorities of a state.”   

Having enacted the PITA, and having provided in its section 85 for the establishment of the SBIR with the responsibility of administering the taxes and duties mentioned, in the above quoted item 7 of part ii of the second schedule to section 4 of the Nigerian Constitution. The National Assemble has ceded its assessment and collection responsibilities in respect of the Personal Incomes taxes to the state. Effectively, therefore, collection of taxes mentioned in the concurrent list now is residual to the state unless the PITA is amended or repealed to reflect otherwise. 
Furthermore on the assessment and collection, once an assessment has been done on a taxpayer, the taxpayer is liable to pay statutorily, the Board or other relevant tax authority does not initially carry out assessment. According to section 41 (1) of the PITA, for each year of assessment, a taxable person shall without notice or demand therefore, file a return of income in the prescribed form and containing the prescribed information with the tax authority of the state in which the taxable person is deemed to be residential. A similar provision is contained in section 41 (1) of the CITA thus: Every company including a company granted exemption from incorporation shall, at least once a year without notice or demand therefore, file a return with the Board.
            The above provision show clearly that the Act require the individual or company to make self-assessment of its source of income and profits. The return must include a statement or declaration that the statement is to the best of the taxpayer’s knowledge, accurate and complete. In the case of a company, the tax authority may accept it and proceed to determine the amount of assessable and process to determine the amount of assessable profits which it proposed to include in the computation of the total profits of the company.
            However, where a company or individual fails to comply with the prescribe form, then the tax authority is empowered to refuse to accept the return and make its own assessment of the individual or company to its best of judgment6. Furthermore, if the bound discovers or is of the opinion that any company liable to tax has not been assessed or has at an amount less than it ought to have been change, the board may within the year of assessment or within six month thereafter, assess such company at such amount or additional amount as ought to has been charged.
            Conclusively, the registration of a taxpayer is one essential procedure that needs to be done by FIRS office given the necessary details that must be provided by the taxpayer on demand. It is required that during registration with any FIRS office, the taxpayer must provide the following documents; a certificate of incorporation issued by C.A.C and bearing an Rc No; necessary document showing the correct business address. Individuals and enterprises are registered under individuals enterprises are registration.

1 Taxes And Levies (Approved List For Collection Act. Cap T2L.E 2004
2 Federal Inland Revenue Service (Establishment) Act (No. 13 of 2007).
3 Ibid
4 Ibid
5 Ibid
6 Section 53(2) of personal income tax act, cap p8 LFN 2004, and section 47(20(b) of companies income tax act cap 21 LFN 2004
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