By Caleb Oboagwina

The unfolding public response to Nigeria’s new tax regime did not come as a surprise. Long before implementation, a careful review of the framework revealed an obvious consequence: resistance. Today, that resistance is visible in subtle but telling ways, such as reluctance to accept bank transfers, refusal to issue receipts, and a gradual retreat into cash-based transactions.

This is not defiance for defiance’s sake. It is society reacting to a law that does not reflect its lived reality.

One of the foundational principles of law is that legislation must grow from the social, economic, and cultural soil of the people it governs. Laws that function efficiently in advanced economies cannot simply be transplanted into Nigeria without adjustment. Context matters. Society matters.

In many developed countries, tax compliance thrives on strong institutional trust, reliable public services, and predictable enforcement. Citizens pay taxes with the confidence that their contributions will translate into tangible benefits such as healthcare, infrastructure, security, and social welfare. Nigeria, regrettably, has not yet built that level of trust at scale.

What we have instead is a largely informal economy populated by small traders, artisans, transport workers, and daily earners whose financial lives are fluid, undocumented, and survival-driven. To impose a rigid, highly formalised tax system on such a society is not reform; it is miscalculation.

When citizens begin to avoid digital transfers or receipts, it is not because they are inherently opposed to taxation. It is because the law feels disconnected, intrusive, and punitive in a setting where the state’s presence is felt more in revenue collection than in service delivery.

Historically, Nigeria has fared better with indirect taxation systems embedded in consumption, such as VAT and excise duties. These mechanisms distribute the tax burden more naturally, reduce daily friction between citizens and government, and capture revenue without turning ordinary survival into a compliance nightmare.

Attempting to leapfrog into an advanced direct-tax compliance culture without first formalising livelihoods, expanding social protections, and rebuilding trust is akin to putting the cart before the horse.

Law without sociology is dangerous. Legislation that ignores social behaviour does not reform society; it drives evasion. Effective laws must be gradual, incentive-based, and educative, not merely coercive.

This brings us to a more troubling question: how national is our National Assembly in outlook? Representation should go beyond geography to include social experience. A legislature that does not fully understand the informal trader, the roadside artisan, or the small business owner risks producing laws that look good on paper but fail on the streets.

Nigeria does not need imported solutions hastily repackaged as reform. What we need is contextual intelligence laws designed with a deep understanding of how Nigerians live, earn, and transact.

Before passing tax laws, policymakers must ask simple but critical questions: How do our people survive? How do they trade? How do they trust or distrust the state?

Until leadership begins to legislate for the Nigeria that exists, rather than the Nigeria it wishes existed, compliance will remain elusive, avoidance will persist, and the law will continue to feel like an adversary rather than a development partner.

Tax reform is necessary. But reform without social understanding is not progress; it is pressure. And pressure, in a fragile economy, produces resistance.

Caleb Oboagwina, a legal practitioner, writes from Lagos