Digital Tax Administration, Taxpayer Awareness, and Voluntary Compliance Among SMEs Under Nigeria's Tax Reform Acts 2025: A Conceptual Framework and Research Agenda

Nigeria's Tax Reform Acts 2025, effective from 1 January 2026, introduce electronic fiscalisation and a universal Taxpayer Identification Number (TIN) requirement. They also extend a zero rate of company income tax to small companies, while excluding professional services firms from that relief. Whether small and medium enterprises (SMEs) will comply voluntarily, rather than under coercion, is theoretically unsettled. This paper develops a conceptual framework that combines the Technology Acceptance Model (TAM) with the Slippery Slope Framework (SSF) and adds Procedural Justice Theory to explain how professional services firms may react to their statutory exclusion. The paper reports no primary data. Six propositions specify digital readiness as a moderator, taxpayer awareness as a mediator, and trust in the Nigeria Revenue Service (NRS) as both a moderator and a partial substitute for enforcement power. The analysis suggests that digital readiness and awareness operate as complementary rather than substitutive conditions for voluntary compliance. The paper contributes to theory by integrating TAM and SSF in a mandatory digital compliance context, and to policy by identifying the professional services exclusion as a source of compliance heterogeneity. A research agenda, with an a priori sample size justification and a mixed-mode design, sets out how the propositions can be tested.