Nigeria

Corporate - Corporate residence

Last reviewed - 28 January 2020

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, or artificial arrangements between related parties or digital company that have a significant economic presence (to be determined by the Minister of Finance) and management, technical, consultancy and professional services that create significant economic presence (to be determined by the Minister of Finance).