Petroleum Taxation and Small-Scale Producers: Evaluating the Marginal Field Programme in Niger State

This study examines the taxation framework applicable to small-scale and marginal field petroleum producers in Niger State, North Central Nigeria, evaluating whether existing fiscal terms under the PIA 2021 and the Marginal Field Regulation 2020 are conducive to sustainable operations. Niger State's frontier petroleum potential has attracted marginal field operators seeking to develop previously stranded assets. Using a descriptive analytical methodology, the research reviews fiscal term provisions applicable to marginal fields, tax compliance records of licensed operators in Niger State, and interviews with four representatives of the Frontier Oil Operators Forum. Financial model comparisons are drawn using public production data from the NUPRC and FIRS tax revenue records from 2021 to 2024. The study finds that royalty rates and income tax obligations, while reduced under the marginal field framework, still present high breakeven risks for operators in frontier basins with limited infrastructure. The research recommends further fiscal incentives for marginal field operators in non-core petroleum states and a streamlined dispute resolution mechanism for tax disagreements. Keywords: petroleum taxation, marginal field, Niger State, PIA 2021, fiscal terms.