NIGERIA Law and Practice Contributed by: Theophilus Emuwa, Jibrin Dasun, Perpetua Onyeukwu and Tubosiya Ibama, ǼLEX
9.11 Country-by-Country Reporting and Transparency Provisions Nigeria favours the OECD proposals for transparency and country-by-country reporting and, among others, has signed the Convention on Mutual Administrative Assistance in Tax Matters, the Country-by-Country Multilateral Competent Authority Agreement, and the Common Reporting Standards Multilateral Competent Authority Agreement. 9.12 Digital Economy Businesses Foreign companies with a digital presence in Nigeria are subject to CIT; see 1.3 Tests for Determining Tax Residence . Payments to NRCs who remotely provide services to Nigerian residents attract a final WHT. The WHT rate can either be 10% or 5%. Technical, management, professional and consultancy services are subject to WHT at 10%, while all other payments attract WHT at 5%.
9.13 Approach to Digital Services Taxation See 9.12 Digital Economy Businesses . 9.14 Offshore IP Provisions WHT of 10% (which is the final tax) applies to all off - shore royalty payments. There are no special rules for IP owners in a tax haven.
408 CHAMBERS.COM
Powered by FlippingBook