- Banking & Financial Services
What applies
- Company Income Tax now governed under the unified Act
- Stronger transfer pricing and arm’s length rules
- Clear taxation of: Interest income, Securities lending transactions, and Derivatives and hedging instruments.
- VAT applies to fee-based services (excluding exempt financial services)
- Stamp duties clarified on: Loan capital, Marketable securities, and Electronic instruments
Impact
- Better clarity on tax treatment of complex financial products
- Increased scrutiny on related-party transactions
- Higher compliance burden for documentation and disclosures
What applies
- Explicit taxation of digital and virtual assets
- Significant Economic Presence (SEP) rule expanded: E-commerce, Online ads, Cloud computing, App stores, and Digital content & online teaching.
- VAT imposed on digital supplies, including non-resident suppliers.
- Losses from digital assets can only offset digital profits
Impact
- Foreign tech companies can now be taxed without physical presence
- Nigerian startups must separate digital asset income clearly
- Stronger compliance for fintech, crypto platforms, and SaaS providers
- NGOs, Foundations & Charities
What applies
- Income tax exemption retained only for qualifying charitable activities
- Commercial or profit-oriented income is taxable
- Donations deductible only if: Made to approved bodies, and Properly documented
- VAT exemptions apply only to specified supplies
Impact
- NGOs must ring-fence charitable vs commercial income
- Higher reporting and record-keeping standards
- Abuse of “NGO status” for business purposes is curtailed
- Oil, Gas & Extractives
What applies
- Petroleum taxation consolidated into the Act
- Covers: Hydrocarbon Tax, Petroleum Profits Tax, and PSCs (deep offshore & inland basins)
- Gas incentives clearly defined
- Decommissioning and abandonment funds recognized
- Fiscal stabilization provisions retained
Impact
- Reduced fragmentation between tax laws
- Better alignment with the Petroleum Industry Act (PIA)
- Improved predictability for investors and operators
- Startups & MSMEs
What applies
- Recognized startups (under Nigeria Startup Act) get: Employment income relief for some foreign staff, and Access to Economic Development Incentive Certificates
- Presumptive tax regime retained for informal MSMEs
- R&D deductions available
- VAT and stamp duty exemptions for qualifying activities
Impact
- Better incentives, but stricter qualification rules
- Startups must maintain proper books earlier in their lifecycle
- Informal businesses face higher risk if records are poor