Nigeria's House of Representatives Public Accounts Committee has intervened in a N123.48 billion dispute between the Nigeria Revenue Service (NRS) and the Tertiary Education Trust Fund (TETFund) over deductions taken as cost of collection on Education Tax. The figure, N123,486,953,796.24, covers excess deductions made between 2012 and 2024. The row surfaced during the committee's review of audit queries on revenue collections and remittances, and it now turns on a single question of statutory interpretation.

What is the dispute about?

At its core is the four per cent cost of collection — an administrative fee the collecting agency may withhold from revenue before remitting the balance to the beneficiary fund. TETFund argues the law permits that fee only on non-oil revenue, not on the entire Education Tax pool.

Dr Gloria Olotu, TETFund's Director of Finance and Accounts, told the committee that the Auditor-General first raised the issue. A subsequent review, she said, found the NRS had applied the four per cent charge to total Education Tax collections without excluding the oil revenue component.

The calculations rested on the NRS's own submissions, which separated the oil and non-oil components of revenue. On that basis, Olotu said, excess deductions across the twelve-year period amounted to N123,486,953,796.24. She added that TETFund had written several letters to the revenue agency seeking resolution but had yet to receive the requested refund.

How does the NRS defend itself?

The revenue service concedes nothing. Shettima Tamadi, Executive Director representing the NRS at the hearing, maintained that no refund is due. His defence rests on Sections 15A and 69 of the NRS Act.

Section 69, Tamadi argued, defines non-oil revenue as all revenue other than that derived from Petroleum Profits Tax (PPT), the levy charged on oil companies' profits. Education Tax paid by oil companies is not PPT, he said, and therefore remains subject to the four per cent deduction. Oil companies pay PPT separately, he noted, and the service does not deduct a cost of collection from those payments.

What does this change for education funding?

In the short term, nothing — and that is the point of contention. If TETFund's reading prevails, more than N123 billion flows back to a fund that finances tertiary infrastructure and academic development. If the NRS interpretation holds, the deductions stay where they are, and TETFund's claims close without payment. Either way, the outcome rests on legal opinion, not on negotiation between the two agencies.

Why the committee deferred a decision

The committee found itself in an awkward position. Members observed that the NRS's interpretation appeared straightforward on an ordinary reading of the provision. Yet the persistence of disagreement between two government agencies over the same text pushed the panel to demand an authoritative ruling.

TETFund told the committee it had already sought a legal opinion from the Attorney-General of the Federation (AGF), the government's chief legal adviser, and would forward the response when received. Unsatisfied with relying on that channel alone, the committee resolved to independently request the AGF's opinion before taking its own decision.

The panel noted that although the relevant law appears to define non-oil revenue, the dispute over its application to Education Tax requires further legal clarification. That is a candid admission: the text, on its face, has not settled the matter.

What happens next

The hearing stands adjourned pending two items — written positions requested from TETFund and the Attorney-General's legal advice. No timeline was given for either submission, and no deadline was set for the committee's return to the question.

The unresolved claim carries consequences beyond accounting hygiene. Every year the dispute drags on, the status quo holds: the NRS keeps the deductions, and TETFund's beneficiaries — Nigeria's public tertiary institutions — wait. Whether the AGF's opinion ends the argument or merely relocates it remains to be seen.