Income tax returns for Nigerian NGOs and charities
The NRS return template for Nigerian NGOs, charities and associations, why exempt bodies still file, and the CAC return that runs alongside it.
By Achekam · · 5 min read · For Accountants & audit firms in Nigeria
Launching soon. Some of the screens this article describes for Nigerian and Kenyan businesses are not reachable in Achekam yet. They are coming soon.
"We are a charity. We don't pay tax." The treasurer of a church-run foundation says it with complete confidence, and for most of the foundation's income she may well be right. What she has missed is that not paying tax and not filing are different things. The NRS publishes a return template specifically for organisations like hers, and the foundation's trustees have a separate filing duty with the Corporate Affairs Commission on top.
Firms that act for NGOs, faith-based organisations, foundations and associations need a clear routine for these clients, because the clients themselves often assume nothing is due.
A separate template for non-profit entities
The NRS's tax returns forms page provides templates for company income tax returns for accounting periods governed by the Nigeria Tax Act, to be completed and uploaded on Rev360. Alongside the standard company template, it provides a further company income tax template for NGOs, charities, foundations, associations and other non-profit entities.
The NRS tax returns forms page holds the official Excel templates for each tax, including the non-profit version, and is the place to download the current template each year rather than reusing last year's file. Templates change, and an upload on an outdated version invites rejection or queries.
Filing even when there is no tax to pay
The NRS's company income tax page says every company, including one exempted from incorporation and one with no tax to pay, must file a self-assessment return with the NRS at least once a year, with or without notice from the NRS.
For a non-profit client, the practical point is that "no tax payable" describes the result of the return, not a reason to skip it. If the client is a company for tax purposes, and the NRS publishes a non-profit template for exactly these organisations, the safe course is to file. Confirm the client's legal form at the start of each engagement, and record on the file why the firm concluded a return is or is not required.
Exemptions must be written in the law
Many non-profits rely on an exemption for some or all of their income. The NRS says the Nigeria Tax Act requires tax exemptions to be expressly provided by law. An exemption cannot rest on custom, on the charitable nature of the work in general terms, or on the fact that the organisation has never been asked to pay.
For each type of income the client receives, the file should show whether it is exempt and the provision that makes it so:
| Income type | Typical question for the file |
|---|---|
| Donations and grants | Which provision exempts them, and does the client meet its conditions? |
| Membership subscriptions | Are they within the exemption, or a payment for services? |
| Rent from property | Is it used for the organisation's objects, or is it a business? |
| Sales from a shop, school or clinic | Is this trading income, and is it exempt? |
| Investment income | Does any exemption extend to interest or dividends? |
Where no provision covers an item, treat it as taxable in the return, and explain the position to the trustees before they see the figure.
Incentive returns where reliefs are claimed
A second NRS filing can apply. The NRS's tax incentives page says every company enjoying a tax incentive, exemption, relief or concession must file annual tax incentive returns with the NRS, whether or not tax is payable for the period, disclosing all incentives claimed in the year.
The wording reaches any company "enjoying" an exemption. A non-profit company that relies on an exemption should therefore consider whether it must also file the incentive return, and the firm should record its conclusion. Assuming the main return covers it is the kind of gap that surfaces years later as a penalty.
The CAC return for incorporated trustees
Many non-profits are registered as incorporated trustees rather than companies. Under the Companies and Allied Matters Act, 2020, the trustees of an incorporated association must submit an annual return to the Corporate Affairs Commission not earlier than 30 June or later than 31 December each year, other than the year of incorporation, accompanied by the audited statement of accounts for the year of return. The return shows the trustees, the council or governing body members, land held and any changes to the constitution, and a default attracts a penalty set by regulation.
The two filings rely on the same audited accounts, so plan them together: the audit finishes, the CAC return is prepared within its window, and the NRS return follows with the same figures. The CAC side is covered in more detail in returns for incorporated trustees.
Setting the client up in Achekam
Non-profit work is easier to manage when it is recognisable in the firm's systems. In Achekam, staff choose an engagement's type when they create it, and a firm can add its own named types. A type such as "Non-profit annual returns" lets the firm see all its NGO clients together at filing time.
For the tax return, staff open a Nigerian tax profile for the client in the Revenue Service Centre and start the return, which moves through prepare, review and approve by different people. Achekam does not file Nigerian tax returns. A person with the firm's NRS filing permission files on Rev360, using the non-profit template, and uploads the receipt; a different person then verifies it before the return counts as filed. The general timetable for company returns is set out in the annual self-assessment return.
A routine for each non-profit client:
- Confirm the legal form: company or incorporated trustees.
- Map each income type to an exemption provision, or mark it taxable.
- Decide whether an incentive return is also required.
- Finish the audit, then prepare the CAC return within its window.
- Download the current non-profit template and prepare the NRS return.
- File on Rev360, upload the receipt, and have a second person verify it.
List the firm's non-profit clients and their legal forms. For each, check whether last year's NRS return was actually filed, on which template, and whether an incentive return was considered; fix any gap before this year's filings begin.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
