Living in Nigeria: reform in effect since January 1, 2026, resident taxed wherever income is generated, rates up to 25%.

This page reports information published by the Nigerian National Assembly, the Federal Ministry of Finance, the Nigerian Investment Promotion Commission (NIPC), the Niger State Tax Administration, and impots.gouv.fr. The Nigerian Tax Act of 2025 (Nigeria Tax Act, 2025) is marked "January 1, 2026" at the beginning of its text: it has been in effect since that date, and the Ministry of Finance specifies that prior periods remain governed by the repealed laws. According to Article 12, the income of a resident is taxable in Nigeria regardless of where it is generated or transferred there. According to the NIPC, the first 800,000 naira (₦) of annual income is exempt, and progressive tax rates apply up to 25 %. The legal residency criterion is not detailed here: Article 12 uses the word "resident" without defining it.

A reform in effect since January 1, 2026

The text of the Nigeria Tax Act, 2025 (Act No. 7 of 2025), published on the National Assembly website, is that of Official Gazette No. 117, Volume 112, dated June 26, 2025. It is headed by the date "[January 1, 2026]". The NIPC presents this Act as a single piece of legislation that replaces, among other things, the Corporate Income Tax Act and the Personal Income Tax Act. The tax administration website indicates that the Nigeria Revenue Service (NRS) replaces the Federal Inland Revenue Service as part of the 2025 reform.

The press release from the Federal Ministry of Finance dated June 18, 2026 sets out the following transition rules:

• Taxes, audits and disputes relating to periods prior to January 1, 2026 fall under repealed laws;
• Declarations for periods ending before this date follow the previous laws, those for periods ending from this date onwards follow the new framework;
• Existing incentives and exemptions remain applicable until their expiry.

The minister clarifies that the new laws do not apply retroactively.

Residence: what Article 12 says

Article 12 of the Nigeria Tax Act, entitled "Resident Individual," stipulates that the income, gains, and profits of an individual resident in Nigeria are deemed to arise and are taxable there, regardless of where they occur or whether they have been repatriated or received in Nigeria. The article contains neither a minimum number of days of residence nor a household requirement. The summary of the law places the definitions in Article 201 ("General Interpretation"), the text of which is not detailed here.

For employment income, Article 13 deems it to be arising in Nigeria in two cases: the employee is a resident of Nigeria, or the functions are performed in whole or in part in Nigeria and the remuneration received during that time is not duly taxed in the employee's country of tax residence.

Between France and Nigeria, Article 4 § 2 of the convention distinguishes between dual residence in this order, according to the text published by impots.gouv.fr: the permanent home, then the center of vital interests, the habitual residence, nationality, then the amicable agreement of the competent authorities.

Income tax: exemptions and progressive rates

Article 58 of the Nigeria Tax Act refers, for the tax due on an individual's taxable income, to the tax schedule of the Fourth Schedule. The table in this schedule is not detailed here. Two official publications summarize its effect:

• The NIPC (publication of January 1, 2026) states that individuals with an annual income of 800,000 or less are exempt, and that the progressive rates, up to 25 %, only apply beyond that;
• The tax administration of the State of Niger writes that the first 800,000₦ of taxable income are taxed at 0 %, the following tranches being taxed from 15 % to 25 % under the law of 2025.

Article 30 lists the deductions allowed when moving from total income to taxable income.

Article 4 includes rents, interest and dividends from Nigerian sources among taxable income.

Non-residents and withholding taxes

Article 17 makes taxable the income, profits, and gains of a non-resident born in or arising from Nigeria. Capital gains on property situated in Nigeria, or deemed to be situated there, are taxable. Withholding tax on payments for services provided from abroad and on insurance premiums is a final tax, unless the payment is attributable to a permanent establishment or significant economic presence in Nigeria (Article 17(3) and (4)).

Article 19 stipulates that no additional tax is due on dividends received by a non-resident from a Nigerian company, beyond the tax withheld at source. The Nigeria Tax Administration Act, 2025, in section 51(2) of the National Assembly text, classifies withholding tax on dividends, interest, rents, royalties, attendance fees, and payments to artists and athletes as a final tax when the recipient is a non-resident. Section 51(1) refers to the withholding tax regulations for the applicable rates. These rates are not detailed here.

The same law requires each taxpayer to have a tax identification number (section 4) and to file a return each tax year, without notice or demand (section 13 (1)).

Capital gains: the regime of Part VIII

Part VIII of the Nigeria Tax Act (sections 33 to 55) deals with capital gains. Section 28(2)(a) classifies an individual's taxable capital gains within their taxable income, along with employment, business, and investment income. The NIPC presents the taxation of individuals as a progressive tax bracket system, up to 25 %. The text does not specify a separate tax rate.

Inheritance, gifts and real estate

The texts cited here do not address the purchase of real estate by a foreigner, nor inheritance or gift taxes. These points are not detailed here. The Franco-Nigerian convention also contains no article on inheritance: its Article 2 only deals with taxes on income, corporations, oil profits, and capital gains.

Coordination with the Franco-Nigerian convention

The convention signed on February 27, 1990 thus caps withholding taxes on the Nigerian side, according to the text published by impots.gouv.fr.

Article 13 allows each state to tax capital gains according to its domestic legislation. Salaries remain taxable in the state of residence if the stay in the other state does not exceed 183 days in any twelve consecutive months and if two other conditions are met (Article 15, paragraph 2). France grants a tax credit equal to the Nigerian tax paid, capped at the corresponding French tax (Article 23). Details can be found on our page dedicated to the convention.

What this page does not cover

This guide does not cover the legal definition of residency, the tax brackets of the Fourth Schedule, withholding tax rates set by regulation, the purchase of property by a foreigner, inheritance tax, state and local taxes, VAT, or residency permits and visas. These points should be verified with the NRS and the relevant state administration. Balmont Conseil is not a law firm or a local tax advisor: local tax matters should be verified with a professional based in Nigeria. French matters, including the departure declaration and the accounts to be declared, are addressed in our pages on tax residency and exit tax.

What changes depending on your situation

• Your status as a resident or non-resident in Nigeria determines the extent of taxable income.
• The nature of your income: salary, dividends, interest, rent, capital gains.
• The year or period concerned, before or after January 1, 2026.
• Your residency situation in France and Nigeria, year by year.

The rule depends on your situation. No results are guaranteed.