Nigeria’s 2025 reform package comprises the Nigeria Tax Act, Nigeria Tax Administration Act, Nigeria Revenue Service (Establishment) Act and Joint Revenue Board (Establishment) Act. The framework became operational in 2026, and the Nigeria Revenue Service replaced FIRS. Historic tax matrices should be reconciled to the new statutes.

The NIPC 2026 incentives guide provides a useful official summary:

• Company income tax is 30% for medium and large companies and 0% for a small company. The guide describes a small company as one with turnover not exceeding NGN100 million and fixed assets not exceeding NGN250 million, subject to the Act’s conditions and exclusions.

• A 4% development levy applies to assessable profits of in-scope companies. NIPC states that small and non-resident companies are excluded. It replaces several former earmarked corporate levies.

• The standard VAT rate remains 7.5%, with statutory zero-rated and exempt categories.

• Company capital gains are taxed at 30%, and indirect transfers can be within scope.

• Personal income tax is progressive up to 25%, with the first NGN800,000 described by NIPC as exempt. PAYE remains administered at state level.

• A 15% minimum effective tax framework applies to qualifying multinational groups and specified large Nigerian businesses. NIPC cites global group turnover of at least EUR750 million or the statutory local threshold.

• Withholding tax depends on the payment and recipient. The NIPC guide confirms 2% for goods, but services, interest, royalties, rent, construction and distributions require the operative deduction-at-source rules.

Cross border and group issues

A foreign company can create Nigerian tax exposure through people, premises, dependent activity or a significant economic presence even without a Nigerian subsidiary. The operating facts should be checked against permanent-establishment and domestic nexus rules.

Intercompany goods, services, loans, licences and royalties require defensible pricing, contracts and evidence. Transfer pricing should be reconciled with customs valuation, withholding tax, foreign-exchange documentation and NOTAP. A year-end adjustment acceptable for one purpose can create a problem for another.

The UK-Nigeria double taxation agreement remains in force. Treaty relief is not automatic. Residence, beneficial ownership, characterisation and Nigerian claim procedures must be satisfied.

Incentives

New Pioneer Status applications have been replaced by the Economic Development Tax Incentive. NIPC describes EDTI as a 5% annual tax credit for five years on qualifying capital expenditure in priority sectors, subject to statutory activity, expenditure, sunset and approval requirements. NIPC published EDTI guidelines and forms in 2026. Eligibility should be assessed before qualifying expenditure is committed.

Implementation checklist

Register with NRS and the relevant state authority; map VAT and withholding by transaction; configure compliant invoices and ledgers; review payroll and benefits; document transfer pricing; test permanent-establishment exposure; analyse financing and interest deductions; preserve treaty evidence; and maintain filing, payment and tax-clearance calendars.