Abstract

The imposition of sales tax by some states in Nigeria has been resisted on the grounds either that a state lacks the power to impose taxes under Nigeria’s constitution or that a state cannot validly impose sales tax as long as the Value Added Tax Act, a federal law, remains in force, the Value Added Tax Act having ‘covered the field’. This article contends that none of these grounds is valid under Nigeria’s constitution: a state government can impose sales tax in exercise of its residual powers; and the doctrine of covering the field is inapplicable in the inquiry.

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