Nigeria: Tax

In an increasingly globalized economy, Double Taxation Agreements (DTAs) serve as critical instruments for fostering cross-border trade, investment, and cooperation

The Deduction of Tax at Source (Withholding Regulations) 2024 (‘the Regulations') provides rules for deduction of tax at source from payment to taxable persons...

A non resident company is a company registered or incorporated under the laws of another country.

The digital economy broadly encompasses economic activities that rely on Internet-protocol (IP) enabled networks and information technologies for creation...

The Federal Government has introduced significant fiscal reforms in the mining sector with the enactment of the Nigeria Tax Act, 2025 (NTA) and the Nigeria Tax Administration Act, 2025 (NTAA). These new laws represent a definitive departure from the previous fiscal regime, which was primarily governed by the Nigerian Minerals and Mining Act, 2007 (the "Mining Act") and the Companies Income Tax Act, 1977 (as amended) (CITA).

Statement of the Problem Recent decisions have emanated from the courts which are to the effect that the exercise of jurisdiction by the TAT as an administrative tribunal...

In recent years, transfer pricing (TP) has emerged as a significant concern for multinational enterprises (MNEs) operating in Nigeria. With the Nigeria Revenue Service (NRS) (formerly Federal Inland Revenue Service) intensifying efforts to generate revenue through taxation, taxpayers face heightened scrutiny, prolonged audits, and increasing risk of double taxation.

Intra-group financing arrangement, particularly interest-bearing loan arrangements, have long been one of the foremost tax planning strategies adopted by multinational enterprises to shift profits from one jurisdiction to another. As a result, tax authorities globally tend to scrutinize these arrangements under transfer pricing rules to ensure that the terms of these transactions are at arm’s length.

Nigeria’s startup ecosystem has established itself as one of the most dynamic in Africa. Despite global headwinds in venture capital markets, funding into African technology companies remained significant in 2024, with Partech reporting that US$3.2 billion was invested across the continent, much of it concentrated in Lagos, a city that now ranks among the leading global hubs for technology talent and entrepreneurial activity.

In a significant overhaul of the Nigerian tax framework, the Nigeria Tax Act, 2025 ("NTA" or "the Act"), among other pieces of legislation, were signed into law by the President of the Federal Republic of Nigeria on 26 June 2025.

As implementation of Nigeria's Tax Reform Acts 2025 (namely The Nigeria Tax Administration Act 2025, The Nigeria Revenue Service Act 2025 and the Joint Revenue Board of Nigeria Act 2025...

Year-end tax compliance has assumed heightened significance for multinational enterprises (MNEs) operating in Nigeria, particularly in the context of increased enforcement activities by the Federal Inland Revenue Service (FIRS)...