Nigeria: Income Tax

The decision of the Federal High Court ("the Court") in Shell Petroleum Development Company of Nigeria Limited v. Federal Inland Revenue Service (FIRS)1 has brought renewed attention to fundamental principles of Nigerian tax law, particularly regarding the proration of tax rates within an accounting year and the retrospective application of tax legislation.

You may have heard about the new tax reform Acts passed by the National Assembly and signed into law by His Excellency, President Bola Ahmed Tinubu GCFR, in June 2025. These reforms come in four key pieces of legislation: the Nigeria Tax Act, the Nigeria Tax Administration Act, the Joint Revenue Board of Nigeria (Establishment) Act, and the Nigeria Revenue Service (Establishment) Act. Taken together, these pieces of legislation represent the most significant overhaul of Nigeria's tax framework in decades

Management fees are a common feature of intra-group arrangements within multinational enterprises (MNEs), reflecting charges for services provided by a parent company or related entity to its subsidiaries. These services are typically designed to promote operational efficiency, ensure consistency in group-wide policies, and allow group entities to benefit from centralized expertise.

Both the Nigeria Tax Act, 2025 and the Nigeria Tax Administration Act, 2025 (the "NTAA") became effective on 1st January, 2026.

On 26 June 2025, the Federal Government of Nigeria signed into law the Nigeria Tax Act, 2025; the Nigeria Tax Administration Act, 2025; the Joint Revenue Board of Nigeria (Establishment) Act, 2025...

With the Nigerian Tax Reform Acts now in full effect for 2026, Nigerians are now operating under a tax framework designed to reduce burdens, encourage compliance, and support economic growth.

On June 26, 2025, President Bola Ahmed Tinubu signed into law a historic package of tax reform legislation, marking the most comprehensive overhaul of Nigeria's fiscal architecture in decades.

On June 26, 2025, President Bola Ahmed Tinubu signed into law four landmark tax reform bills that fundamentally reshape Nigeria's revenue administration landscape.

Nigeria's new tax regime fundamentally reshapes how intellectual property (IP) and digital assets are taxed. If your startup earns revenue from software, data, digital platforms...