Africa & Indian Ocean · West Africa

Nigeria

This is a wealth-source market, not a wealth-destination market. Our clients' exposure here should be outbound. Nigeria offers no permanent residence, a rank-90 passport, and, from January 2026, a tax code that has abolished the capital/income distinction entirely.

Last verified July 202644 visa-free destinations

Frequently asked

Does Nigeria offer permanent residence?

Not any longer. The flat no is out of date. Historically Nigeria had no permanent residence, and the N3A-N3E investor visas remain term-limited, multiple-entry residence permits (the N3E oil, gas and power class carries a ten-year stay). The everyday CERPAC, USD 2,000 per employed expatriate, renewable annually, is perpetually renewable but never itself becomes permanent. In June 2023, though, the Federal Ministry of Interior introduced the Brown Card Permanent Residence Permit under the Nigeria Visa Policy 2020. It confers indefinite residence without the old renewal cycle on qualifying investors, persons of African descent under the Privilege of Return, the exceptionally talented, and certain foreign spouses. Implementation has been slow and the procedural detail thin, and it confers no citizenship. Still, it is no longer accurate to say Nigeria has no permanent residence at all. We cover Nigeria chiefly to advise against it as a wealth destination rather than a wealth source.

What changed in Nigeria's 2026 tax reform?

A great deal, and it is the most consequential change in West Africa. Four acts signed on 26 June 2025 took effect on 1 January 2026 (the Federal Inland Revenue Service became the Nigeria Revenue Service). The separate capital and income distinction was abolished. Individuals' gains are now added to income and taxed at progressive rates up to 25%, a 2.5x increase on the old 10% flat CGT. Indirect offshore transfers are now taxable too, closing the classic structure of holding Nigerian assets through an offshore holdco and selling the holdco instead.

Is there a Nigerian citizenship by investment?

No, it has no constitutional basis. Chapter III of the Constitution provides only for birth, registration and naturalisation. An official Ministry of Interior page publishes requirements for acquiring citizenship by investment at USD 1,000,000, but this is for a route that does not legally exist. The proposed HB 2059 passed second reading on 26 March 2025. It specifies no threshold, and would need two-thirds of both chambers plus two-thirds of 36 State Houses of Assembly to pass. The USD 300,000 Nigeria CBI figure that appears on agency sites seems to be fabricated.

Can I be caught as a Nigerian tax resident without spending 183 days there?

Yes. The residency net widens from 1 January 2026. You count as resident if you are domiciled in Nigeria, or a permanent home is available to you there, or you have a habitual abode there, or you spend 183 days in the country. You also count as resident if you have substantial economic ties or immediate family ties in Nigeria. An investor holding USD 250k+ of retained capital, plus family in the country, can therefore be pulled into worldwide tax residency on well under 183 days. Residents are taxed on worldwide income. The investor visa and the residency test interact badly, and they interact worst for exactly the people the visa is meant to attract.

If I naturalise as Nigerian, can I keep my other citizenships?

Only citizenship held by birth. The common claim that a naturalised Nigerian must renounce all other citizenships is wrong. They may keep a foreign citizenship held by birth. But any citizenship acquired afterward must be renounced within five months, and a naturalised Nigerian who later acquires a new citizenship forfeits Nigerian citizenship immediately. For anyone running a portfolio-of-citizenships strategy, Nigerian naturalisation actively works against that goal. Section 30 also allows naturalised citizens to be stripped of citizenship for disloyalty shown by act or speech.

How strong is the Nigerian passport?

Weak — rank 90 on the Henley Passport Index for June 2026, with 44 visa-free destinations, below both Ghana and The Gambia. Combined with the absence of any permanent-residence status and a 15-year, fully discretionary naturalisation route requiring a State Governor's opinion that the applicant is 'acceptable to the local community', there is no meaningful mobility or status case for acquiring Nigerian nationality. The millionaire population contracted 47% over the decade to 7,200 residents — the smart money is leaving.

Can a Nigerian resident invest freely in foreign markets?

No, and for a globally invested family this is disqualifying on its own. A Nigerian resident is legally restricted from buying foreign exchange to invest in foreign-currency securities abroad. Add to that the 2026 taxation of indirect offshore transfers and a 25% top personal rate that bites above roughly USD 33,000 (NGN 50m), and a UHNW client's exposure to Nigeria should be structured as outbound, not as a relocation or investment destination.

Tax position

Income tax (top)
25% above NGN 50m (roughly USD 33k, meaning every UHNW client is at the top rate from day one)
Capital gains
The separate capital/income distinction was abolished from 1 January 2026. Individuals' gains are now added to income and taxed at progressive rates up to 25%, a 2.5x increase on the old 10% flat CGT. Indirect offshore transfers are now taxable.
Wealth tax
None
Inheritance tax
none, with a market-value cost-base reset at death
Special regime
There is no special regime. In 2026 the residency net widened to include anyone with substantial economic ties or immediate family ties in Nigeria, regardless of how many days they actually spend in the country.
Territorial
No, worldwide income taxed
CFC rules
Yes
Exit tax
No
CRS
Participating

Is Nigeria actually right for your family?

We will tell you if it is not. That is the whole service.

Book a consultation