Under the Nigeria Tax Administration Act 2025 (effective January 2026), documentation is the bridge between "taking the money" and "proving you paid it." The system is now heavily digital, making physical and electronic records equally important.
To be fully compliant, you need documentation for two different roles: as a Payer (the one deducting) and as a Beneficiary (the one being deducted).
1. Documentation You Need as a PAYER (Deductor)
If you are paying a consultant or supplier and deducting WHT, you must maintain these records for 6 years:
- Supplier's Tax ID (TIN): You must have the vendor's valid TIN. Under the new law, awarding a contract to a vendor without a TIN can attract a fine of ₦5 million.
- The Invoice: A clear breakdown of the gross amount.
- Tip: If the invoice separates "professional fees" from "reimbursable expenses" (like flight tickets), you only need to document the WHT on the fee.
- Payment Evidence: Bank transfer slips or Remita RRR (Retrieval Reference Number) receipts showing the net payment to the vendor.
- WHT Monthly Schedule: A digital or physical spreadsheet showing:
- Vendor Name and TIN.
- Nature of transaction (e.g., "Consultancy" or "Supply").
- Gross amount, WHT rate (e.g., 2% or 5%), and WHT amount.
- NRS Remittance Receipt: The electronic receipt generated by the Nigeria Revenue Service (NRS) portal after you pay the deducted tax.
2. Documentation You Need as a BENEFICIARY (The one being paid)
If a client deducts WHT from your payment, you need these to ensure you don't lose that money to the government:
- WHT Credit Note: This is the most important document. It is a certificate issued by the NRS (not the client) proving that the tax was actually remitted on your behalf. You need this to reduce your end-of-year tax bill.
- Self-Certification Letter: As a small business, you should keep copies of the letters you send to clients claiming your "Small Company" exemption status.
- Correspondence/Contracts: Keep the contract or purchase order that shows the agreed WHT rate. This helps if a client mistakenly deducts 5% instead of the new 2% for supplies.
3. The "New Law" Compliance Checklist (2026)
| Document | Purpose | Importance |
|---|---|---|
| Active TIN | Required for all filings | Mandatory |
| Electronic Schedule | For uploading to the NRS portal | High |
| Proof of Remittance | To avoid the 10% late penalty | Critical |
| Audit File | Collection of invoices/receipts (6-year history) | Legal Requirement |
Warning on Digital Records
The 2025 Act specifically empowers the NRS to demand access to your electronic accounting records. If you keep your records on a computer or cloud software (like QuickBooks or Zoho), you must be able to produce them for a tax officer upon request. Failure to grant access can lead to a fine of ₦20 million.