Nigeria · Tax regime
Nigeria Tax Act 2025
In force. Four acts signed on 26 June 2025, effective 1 January 2026. The Federal Inland Revenue Service became the Nigeria Revenue Service. Transition guidelines confirm no retrospective application. This is the most consequential tax change in the region alongside Mauritius's.
For families with Nigerian assets or family ties this is the most important development in West Africa. The abolition of the capital/income distinction and the taxation of indirect offshore transfers together close the standard exit structure, and the widened residency test can pull in people who are nowhere near 183 days.
Qualifying routes
top rate 25% above NGN 50m; Consolidated Relief Allowance abolished; minimum tax abolished
flat 10% CGT repealed; gains added to income at progressive rates to 25%; indirect offshore transfers now taxable
retained at 7.5% with expanded zero-rating and full input recovery — genuinely competitive
The facts
- Total landed cost
- Not applicable — a tax regime, not a programme
- Physical presence
- The residency test now catches 'substantial economic ties or immediate family ties' regardless of day count
- Family
- not applicable
- Permanent residency
- not applicable
- Citizenship
- not applicable
- Language test
- not applicable
- Dual citizenship
- Not permitted — you would have to renounce
- Indirect offshore transfers are now taxable. The classic structure — hold Nigerian assets through an offshore holdco and sell the holdco — no longer works.
- The shares de minimis is a retail carve-out and meaningless at UHNW scale: it requires BOTH proceeds below NGN 150m (roughly USD 100k) AND gains at or below NGN 10m (roughly USD 6.6k).
- The top personal rate of 25% bites above NGN 50m — roughly USD 33,000. Every UHNW client is at the top rate immediately.
- The widened residency test ('substantial economic ties or immediate family ties') is a genuine trap for non-resident Nigerians with family and property at home.
- Nigeria is an active CRS sender to 81 partners.
- CFC rules exist but appear corporate-only under section 6(2); whether they reach individuals could not be established.