Nigeria: Tax

The August 2026 issue of TEMPLARS Tax Transcripts examines developments in treaty policy, fiscal administration, and stamp duty adjudication as Nigeria continues to align administrative practice with its new tax statutes. Key updates include the signing of a Double Taxation Agreement between Nigeria and Hong Kong, the commencement of the Green Tax surcharge on imported high-engine vehicles, and the Accountant-General's directive to discontinue the 1% stamp duty deduction on payments to contractors, vendors

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...

Nigeria's new tax framework, effective January 1, 2026, introduces comprehensive regulations for non-resident individuals earning income from Nigerian sources. Understanding the criteria for non-resident status, tax obligations, registration requirements, and filing procedures is essential for expatriates and foreign workers operating in Nigeria's evolving tax landscape.

The Nigeria Tax Administration Act 2025 introduced sweeping reforms within the Nigerian Tax Regime, one of which is the “power of substitution” as contained in Section 60 of the Act.

For the better part of June and July 2026, the FIFA World Cup had the world enthralled with nerve-racking matches, record-breaking performances and celebrations that stretched far beyond the stadiums. But while fans counted goals, another spectator was keeping a different score – the taxman. The tournament ended weeks ago, but for the players, the story did not end on the pitch. In its wake, athletes were faced with taxation tied to the sporting activities they performed in host countries, and for those who played on American soil, this meant up to 37% of their earnings, in some cases, going to the taxman.

Nigeria's tax landscape has transformed with the Nigeria Tax Act 2025 and Nigeria Tax Administration Act 2025, introducing a comprehensive framework for collective investment schemes. These reforms consolidate previously fragmented tax provisions, exempt dividends from authorised CISs, and create greater certainty for fund managers, trustees, and investors in Nigeria's capital markets.

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 new tax regime introduces critical compliance requirements for incorporated companies that have not yet commenced business operations. The Nigeria Tax Act 2025 and Nigeria Tax Administration Act 2025, effective January 1, 2026, reshape the framework for corporate taxation and administration, raising important questions about filing obligations for shelf companies and non-operational entities.

TotalEnergies and AMNI have taken the Final Investment Decision on Nigeria's Ima Gas Project, a development 53 years in the making that will supply critical feed gas to Nigeria LNG's Train 7 expansion. Between FID and first gas in 2028, the project faces complex legal obligations spanning financing conditions, gas sales agreements, construction contracts, Nigerian content compliance, host community trusts, flaring regulations, and tax incentives that must all hold up in practice.

Nigeria's 2025 Tax Reform Acts introduce sweeping changes for non-residents, foreign investors, and expatriates operating in or deriving income from Nigeria. From expanded Permanent Establishment rules and Significant Economic Presence thresholds to mandatory VAT registration for offshore suppliers and Capital Gains Tax on indirect share transfers, the new framework fundamentally reshapes cross-border tax obligations. Understanding these provisions and taking proactive compliance steps is now essential for