Nigeria

A company is considered resident in Nigeria if such a company is registered or incorporated under the Companies and Allied Matters Act. This means that a company formed outside Nigeria under the laws in force in the foreign territory will be considered as a non-resident company for CIT purposes.

Permanent establishment (PE)

Fixed base is not defined but is generally considered to be a location with a degree of permanence. The following would generally not be considered to be a fixed base:

• The use of facilities solely for the purpose of storage or display of goods or merchandise.
• The use of facilities solely for the collection of information.

Other activities that could trigger a tax presence in Nigeria include a dependent agency arrangement, execution of a turnkey project, artificial arrangements between related parties, or digital companies that have a significant economic presence (as determined by the Minister of Finance) and management, technical, consultancy, and professional services that create significant economic presence (as determined by the Minister of Finance).