Nigeria · Tax regime
Nigeria Tax Act 2025
In force. Four acts were signed on 26 June 2025 and take effect on 1 January 2026. The Federal Inland Revenue Service has become the Nigeria Revenue Service. Transition guidelines confirm there is no retrospective application. Alongside Mauritius's changes, this is the most consequential tax reform in the region.
For families with Nigerian assets or family ties, this is the most important development in West Africa. The abolition of the capital and income distinction, combined with the new tax on indirect offshore transfers, closes off the standard exit structure. The widened residency test can also pull in people who are nowhere near 183 days.
Qualifying routes
Top rate of 25% above NGN 50m. The Consolidated Relief Allowance has been abolished. The minimum tax has also been abolished.
The flat 10% CGT has been repealed. Gains are now added to income and taxed at progressive rates up to 25%. Indirect offshore transfers are now taxable too.
Retained at 7.5%, but with expanded zero-rating and full input recovery. It is genuinely competitive.
The facts
- Total landed cost
- Not applicable. This is a tax regime, not a programme.
- Route type
- Tax regime, not a visa
- Physical presence
- The residency test now catches substantial economic ties or immediate family ties, regardless of how many days you spend in the country.
- 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, holding Nigerian assets through an offshore holding company and then selling the holding company, no longer works.
- The shares de minimis is a retail carve-out and means little 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% kicks in above NGN 50m, roughly USD 33,000. Every UHNW client hits the top rate immediately.
- The widened residency test, based on substantial economic ties or immediate family ties, is a genuine trap for non-resident Nigerians who still have family and property at home.
- Nigeria actively sends CRS data to 81 partners.
- CFC rules exist but appear to be corporate-only under section 6(2). Whether they extend to individuals could not be established.