Nigeria Tax Reform Act 2025

A Guide for Cross-Border Earners
Understanding how the new tax rules affect you if your income or assets are connected to Nigeria.​

The Act may apply to you if you:

  • Are a Nigerian citizen or resident, and
  • Earn income from Nigeria, or
  • Own property, investments, or a business in Nigeria, or
  • Spend significant time in Nigeria

Living abroad does not automatically remove Nigerian tax obligations.

No, if all of the following are true:

  • You are not a Nigerian tax resident, and
  • The income is earned outside Nigeria

Example:
Ada works and earns her salary in the UK → Not taxable in Nigeria.

Important exception:
If you work while physically present in Nigeria for 183 days or more within a 12-month period, income earned during that time may be taxable.

You are a Nigerian tax resident if any of the following apply:

  • You spend 183 days or more in Nigeria within 12 months
  • You maintain a permanent home in Nigeria
  • You have significant family or economic ties in Nigeria

Residency is determined by presence, housing, and economic connection, not citizenship alone.

A permanent home is a place in Nigeria that is available to you at any time, such as:

  • A house you own
  • A rented property available year-round
  • A family home you can freely use

Short-term or occasional accommodation does not qualify.

No.
Short stays and temporary rentals do not create tax residency unless they are used consistently and long-term.

Personal remittances are not taxable, including money sent for:

  • Family support
  • School fees
  • Living expenses

Remittances may be taxable if they are sent for:

  • Business investment
  • Purchasing goods for resale
  • Funding business operations

Yes. From January 1, 2026, all bank accounts must be linked to a TIN.

  • Your NIN (individuals) or CAC number (businesses) may serve as your TIN if applicable.

No, if:

  • The work is performed entirely outside Nigeria

Example:
Chichi works from Canada for a Lagos company → Not taxable.
If Chichi works while in Nigeria for 183 days or more, income earned during that period may be taxed.

Yes.
Income earned while physically working in Nigeria is considered Nigerian-sourced and may be taxed.

Yes.
Rental income from Nigerian property is taxable regardless of where you live.

Capital Gains Tax (CGT) applies, not on the total sale value.

Example:
Bought at ₦50 million, sold at ₦70 million → CGT applies to ₦20 million.

  • ⁠ ⁠Dividends → Taxable
  • With respect to disposal of shares, if the proceeds on disposal is ₦150m and below and the gains on disposal is less than 10m in a 12-month period, then it is exempt from Capital Gains Tax (CGT).
  • ⁠If the proceeds from such a disposal, regardless of the threshold, are reinvested in acquiring shares of the same or other Nigerian companies within a consecutive 12 months period, you can defer paying CGT until a later date

Yes, if the value of those shares is primarily derived from Nigerian assets.
This applies even if the sale occurs outside Nigeria.

No, if:

  • You live abroad
  • Work for foreign clients
  • Earn income outside Nigeria

You may be taxed if:

  • You work for Nigerian clients, or
  • You perform the work while in Nigeria for 183 days or more

Generally no, unless the business:

  • Operates in Nigeria
  • Has employees, agents, or warehouses in Nigeria
  • Targets Nigerian customers digitally
  • Owns Nigerian assets

Spending 183 days or more in Nigeria within any 12-month period makes you a Nigerian tax resident.

The days do not need to be consecutive.

Economic ties include:

  • Business operations
  • Property ownership
  • Active investments
  • Ongoing financial support
Persona Country Scenario Taxed in Nigeria?
Ada UK Works for UK firm No
Funmi UK Works from Lagos 6 months Yes (only for days worked)
Uche US Lagos landlord Yes
Nnamdi Canada Sends money for family No
Nnamdi Canada Sends money for business Possibly
Aisha UAE Sells Nigerian shares Yes
Aisha UAE Gains ≤ ₦150M No
Income Type Taxed in Nigeria?
Foreign salary earned abroad No
Personal remittances No
Salary earned in Nigeria Yes
Rent from Nigeria Yes
Business profits from Nigeria Yes
Capital gains on Nigerian assets Yes
Capital gains on foreign shares linked to Nigeria Yes
Capital gains ≤ ₦150M No (exempt)
Reinvested capital gains No (deferred)
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