By Enyichukwu Enemanna
The recent Memorandum of Understanding (MoU) recently signed by Nigeria’s foremost revenue-generating agency, the Federal Inland Revenue Service (FIRS) with French Direction Générale des Finances Publiques (DGFiP) is still controversy with some notable individuals calling for its suspension.
The DGFiP (Directorate General of Public Finances) is an agency of the French government that plays a key role in public finance management, including taxes.
On December 10, Nigeria’s FIRS signed a MoU with the DGFiP on the promotion of efficient tax administration, a move that has generated controversy.
The agreement is aimed at providing access to advanced tools such as AI-powered audits, automated compliance systems and real-time economic analytics.
On Sunday, a regional bloc, Northern Elders Forum (NEF) called for immediate suspension of the agreement, warning that it poses a grave threat to Nigeria’s economic sovereignty and national security, an allegation the Service denies.
Adding his voice to the debate, a former Managing Director of Transmission Company of Nigeria (TCN), Dr. UG Mohammed described the MoU as a “misalignment” that will create legal incompatibility, urging that it should be discarded.
“Nigeria’s legal and tax system is rooted in the common law tradition, inherited from the UK. Our tax statutes, interpretation principles, dispute resolution mechanisms, and even administrative practices are shaped by precedent, judicial interpretation, and adversarial processes. In contrast, France operates a civil law system, where tax law is highly codified, administrative discretion is wider, and courts play a more limited interpretive role”, Dr. Mohammed stated in a release on Sunday.
He emphasized that French tax law is designed to function within a civil law ecosystem, with centralized administration, strong bureaucratic authority, and limited reliance on case law, underlining that transplanting concepts from such a system into Nigeria’s common law–based framework risks interpretational conflicts, uncertainty in enforcement and what he referred to as prolonged litigation, as courts struggle to reconcile civil-law concepts with common-law principles.
He added, “Civil-law tax systems often vest substantial powers in tax authorities. In Nigeria—where institutional checks are still evolving—this could exacerbate arbitrariness, undermine taxpayer confidence and increase disputes rather than compliance.”
He queried the specific problem France being used to solve in the Nigeria’s tax system and why it is the most suitable solution within Nigeria’s legal and institutional reality.
In conclusion, Dr. Mohammed said France may be efficient, but efficiency alone is not a sufficient justification, adding that legal compatibility, institutional fit, and ease of integration matter more.
According to him, from that standpoint, UK, Singapore, and Malaysia are “far more defensible” reference points for Nigerian tax reform collaboration than France.
FIRS Reacts
But in a statement on Sunday, the FIRS clarified some of the concerns analysts have raised with regards to the MoU.
“MoU is a standard, globally recognised cooperation framework focused solely on technical assistance and capacity building,” the service said.
“It does not grant France access to Nigerian taxpayers’ data, digital systems, or any element of our operational infrastructure.
“All existing Nigerian laws on data protection, cybersecurity, and sovereignty remain fully applicable and strictly enforced.
“The Nigeria Revenue Service (NRS), like its predecessor (FIRS), places the highest premium on national security and maintains rigorous standards for the protection of all taxpayers’ information.”
The FIRS said the MoU signed with France’s DGFiP is to leverage France’s over a century of expertise in digital transformation, taxpayer services, governance, and public finance.
“It is advisory, non-intrusive, and entirely under Nigeria’s control. Contrary to misconceptions, the MoU does not displace local technology providers,” the service said.
