🇳🇬 Nigeria
Sub-Saharan Africa · ISORA participant ·
Nigeria’s tax enforcement framework includes statutory interest limitation rules and country-by-country reporting requirements, alongside the practical application of automated bulk data matching. The country does not currently enforce controlled foreign company rules. In 2021, tax revenue accounted for 6.7% of the nation's GDP.Auto-generated summary of the verified data below; every fact traces to a source on this page.
6.7%
tax-to-GDP, general govt (2021, OECD)
7/11
enforcement powers assessed
Where the tax bite lands (2021)
Tax revenue by category, % of GDP, general government — OECD Revenue Statistics (Global).
Who collects it (2021)
| Level of government | % of GDP |
|---|---|
| Central government | 5.1% |
| State/regional government | 1.1% |
| Social security funds | 0.5% |
| State/regional government | 0.0% |
Tax-to-GDP over time
| 2010 | 2019 | 2021 |
|---|---|---|
| 7.3% | 6.0% | 6.7% |
General government, OECD Revenue Statistics (Global).
Headline statutory rates
As stated in PwC Worldwide Tax Summaries’ territory overview (fetched 2026-08-20) — the wording is PwC’s; source.
| Tax | Headline rate as stated |
|---|---|
| Headline PIT rate | 25 |
| Headline CIT rate | 30 for large companies; 0 for small companies |
| Standard VAT rate | 7.5 |
| Headline individual capital gains tax rate | Same as PIT rates as CGT has now been harmonised with the income tax rate for individuals. |
| Headline corporate capital gains tax rate | Same as CIT rates as CGT has now been harmonised with the income tax rates for companies. |
| WHT rates (%) (Dividends/Interest/Royalties) | Resident: 10 / 10 / 10; Non-resident: 10 / 10 / 10; For non-residents, the WHT rate will be reduced to 7.5% through the use of a DTT with certain territories. |
| Headline net wealth/worth tax rate | NA |
| Headline inheritance tax rate | NA |
| Headline gift tax rate | NA NA stands for Not Applicable (i.e. the territory does not have the indicated tax or requirement) NP stands for Not Provided (i.e. the information is not currently provided in this chart) |
Enforcement powers
Automated bulk data matching Yes — documented practice
Self-reported to ISORA (International Survey on Revenue Administration), FY2022.
“ISORA indicator "Administration undertakes fully automated compliance checks based on data matching/analysis" — value: Yes”
Source: IMF ISORA — International Survey on Revenue AdministrationOECD / IMF survey data · derived from the administration’s own survey answer
Crypto-asset reporting Partial / committed
Listed by the OECD Global Forum as committed to implement the Crypto-Asset Reporting Framework in time for first exchanges by 2028 (list updated 17 June 2025).
“Mongolia, Nigeria, the Philippines”
Source: OECD Global Forum — Jurisdictions committed to implement the Crypto-Asset Reporting FrameworkOfficial source · quote machine-verified 2026-08-25
Citizenship-based taxation No — power absent
Nigeria taxes individuals by residence, not citizenship (PwC Worldwide Tax Summaries).
“Individuals resident in Nigeria are taxed on their worldwide income.”
Source: PwC Worldwide Tax Summaries — NigeriaProfessional / legal analysis · quote machine-verified 2026-08-25
Controlled foreign company (CFC) rules No — power absent
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there a controlled foreign company rule in place? · Not applicable" — No”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Interest limitation rules Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there an interest limitation rule in place? · Regime 1" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Country-by-country reporting Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (0).
“OECD Corporate Tax Statistics: "Is there a country-by-country reporting law in place?" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Public naming of non-compliant taxpayers Yes — statutory power
Self-reported to ISORA (International Survey on Revenue Administration), FY2022.
“ISORA indicator "Administration is empowered to make public details of some / all taxpayers subject to administrative penalties imposed for non-disclosure" — value: Yes”
Source: IMF ISORA — International Survey on Revenue AdministrationOECD / IMF survey data · derived from the administration’s own survey answer
Anti-avoidance regime detail (OECD Corporate Tax Statistics)
OECD-curated descriptions of this jurisdiction’s CFC, interest-limitation, CbCR and IP-regime rules.
CFC rules — 2 data points
| Is there a controlled foreign company rule in place? · Regime 1 | No |
| Is there a controlled foreign company rule in place? · Not applicable | No |
Interest limitation — 37 data points
| Number of years allowed under carry forward/back. · Regime 1 | 5 years |
| Number of years allowed under carry forward/back. · Rule 1 | 5 years |
| Do any loss carry-back or carry-forward provisions apply? · Regime 1 | Yes |
| Do any loss carry-back or carry-forward provisions apply? · Rule 1 | Yes |
| Is a de minimis threshold present? · Regime 1 | No De minimis threshold |
| Is a de minimis threshold present? · Rule 1 | The rule does not apply to a Nigerian subsidiary of a foreign company which is engaged in the business of banking or insurance. |
| Any other exclusions? · Regime 1 | No |
| Any other exclusions? · Rule 1 | No |
| Exclusions based on payer characteristics? · Regime 1 | Yes |
| Exclusions based on payer characteristics? · Rule 1 | Yes |
| Exclusions based on payment characteristics? · Regime 1 | No |
| Exclusions based on payment characteristics? · Rule 1 | No |
| Exclusions based on recipient characteristics? · Regime 1 | Yes |
| Exclusions based on recipient characteristics? · Rule 1 | Yes |
| Financial accounting measure applied to rule · Regime 1 | interest-to-EBITDA |
| Financial accounting measure applied to rule · Rule 1 | interest-to-EBITDA |
| Is there a group ratio rule or similar type of rule in place? · Regime 1 | No |
| Is there a group ratio rule or similar type of rule in place? · Rule 1 | No |
| Is there an interest limitation rule in place? · Regime 1 | Yes |
| Is there an interest limitation rule in place? · Rule 1 | Yes |
| Can interest be recharacterised as a dividend? · Regime 1 | No |
| Can interest be recharacterised as a dividend? · Rule 1 | No |
| Is the rule is applicable to net or gross interest expensing? · Regime 1 | Gross |
| Is the rule is applicable to net or gross interest expensing? · Rule 1 | Gross interest expense |
| Is the rule applicable to related party debt? · Regime 1 | No |
| Is the rule applicable to related party debt? · Rule 1 | No |
| Description of interest limitation rule · Regime 1 | The domestic law in Nigeria sets a limit on the amount of interest that can be deducted for tax purposes, particularly in cases of related-party or connected-party financing arrangements, to prevent excessive profit shifting. The deductible interest is limited to 30% percent of earning before interest, taxes, depreciation and amortization of the Nigerian company in that accounting period. |
| Description of interest limitation rule · Rule 1 | The domestic law in Nigeria sets a limit on the amount of interest that can be deducted for tax purposes, particularly in cases of related-party or connected-party financing arrangements, to prevent excessive profit shifting. The deductible interest is limited to 30% percent of earning before interest, taxes, depreciation and amortization of the Nigerian company in that accounting period. |
| Type of interest limitation rule · Regime 1 | Fixed ratio rule |
| Type of interest limitation rule · Rule 1 | Deductible Interest |
| Financial ratio referenced · Regime 1 | 0.3 |
| Financial ratio referenced · Rule 1 | 3:1 |
| Is the rule is applicable to third party debt? · Regime 1 | No |
| Is the rule is applicable to third party debt? · Rule 1 | No |
| Are there targeted rules to address specific risks not addressed by the general rule? · Regime 1 | No |
| Are there targeted rules to address specific risks not addressed by the general rule? · Rule 1 | No |
| Year of introduction of the interest limitation rule · Rule 1 | 2019 |
Country-by-country reporting — 4 data points
| Is there a country-by-country reporting law in place? | Yes |
| Deadline by which filings must be submitted | 12 months |
| Reports are required for MNEs with annual revenues above | NGN 160 billion |
| Headquarter jurisidiction filing required from | 01-Jan-18 |
Effective corporate tax rates
| Measure | Year | Rate |
|---|---|---|
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 25.3% |
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 18.9% |
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 25.3% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 28.0% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 24.7% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 28.0% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 40.6% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 35.7% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 35.5% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 31.5% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 35.4% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 27.7% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 26.7% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 28.6% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 25.1% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 25.5% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2021 | 86.7% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2021 | 16.3% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2021 | 27.2% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2021 | -42.4% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2021 | -6.4% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 21.1% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 11.8% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 30.0% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | -4.1% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 0.3% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | -3.6% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | -4.9% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | -5.0% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | -6.2% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | -5.0% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 3.6% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 3.4% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 3.9% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 2.9% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 3.0% |
OECD Corporate Tax Statistics, baseline scenario.
Administration self-reported metrics (ISORA)
Reported by the administration itself to the IMF/OECD/CIAT/IOTA International Survey on Revenue Administration. 1 = yes, 0 = no for policy questions.
| Indicator | Year | Value |
|---|---|---|
| Percentage of tax returns - Electronic, not prefilled - CIT | 2024 | 100 |
| Percentage of tax returns - Electronic, not prefilled - PIT | 2024 | 100 |
| Percentage of tax returns - Electronic, not prefilled - VAT | 2024 | 100 |
| Population per FTE | 2024 | 22496.323890554 |
| Labor force per FTE | 2024 | 10959.06062070966 |
| Corporate taxpayers per FTE in LTO/P | 2024 | 3.154166666666667 |
| Active taxpayers on PIT register as percentage of Population | 2024 | 0.1852819181586784 |
| Active taxpayers on PIT register as percentage of Labor Force | 2024 | 0.3803393544592726 |
| Closing stock of collectable arrears as percentage of closing stock of arrears | 2024 | 100 |
| CIT arrears as percentage of CIT collected | 2024 | 0.8656466305004901 |
| PIT arrears as percentage of PIT collected | 2024 | 0 |
| PAYE arrears as percentage of PIT collected | 2024 | 0 |
| VAT arrears as percentage of VAT collected | 2024 | 0.8659118327226004 |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - CIT | 2021 | — |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - CIT | 2021 | — |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - CIT | 2021 | — |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - PIT | 2021 | — |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - PIT | 2021 | — |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - PIT | 2021 | — |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - VAT | 2021 | — |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - VAT | 2021 | — |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - VAT | 2021 | — |
| Additional assessments raised through all audits and verification actions as percentage of tax collections | 2024 | 4.424749847153939 |
| Audit hit rate | 2024 | 99.74312481112118 |
| Percentage of tax returns - Electronic, not prefilled - PAYE | 2024 | 100 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, not modified by taxpayer - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - PIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - PIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - PAYE | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - PAYE | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - VAT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - VAT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - PIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - PAYE | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - VAT | 2024 | 0 |
| Availability of specific powers in legislation / regulation to assist in collecting tax arrears | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Common administrative penalty framework for non-disclosure across the major tax types | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Penalties imposed generally take account of taxpayers' culpability (i.e. degree of blame) | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Administration is empowered to remit / reduce penalties in appropriate circumstances | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Administration is empowered to make public details of some / all taxpayers subject to administrative penalties imposed for non-disclosure | 2022 | 1 |
| On-time filing rate % - CIT | 2024 | 94.08000281790265 |
| On-time filing rate % - PIT | 2024 | 60.35007063113383 |
| On-time filing rate % - VAT | 2024 | 79.04994899981737 |
| On-time filing rate % - PAYE | 2024 | 95.05567338282079 |
| Administration pre-fills PIT returns or assessments | 2024 | 0 |
| Administration conducts random audits | 2022 | 1 |
| E-filing mandatory - CIT | 2022 | 1 |
| E-filing mandatory - PIT | 2022 | 1 |
| E-filing mandatory - Employer Withholdings | 2022 | 1 |
| E-filing mandatory - VAT | 2022 | 1 |
| E-payment mandatory - CIT | 2022 | 1 |
| E-payment mandatory - PIT | 2022 | 1 |
| E-payment mandatory - Employer Withholdings | 2022 | 1 |
| E-payment mandatory - VAT | 2022 | 1 |
| Employers withholding taxes on behalf of salaried employees | 2024 | 1 |
| Percentage of payments received electronically-By number of payments | 2024 | 100 |
| Percentage of payments received electronically-By value of payments | 2024 | 100 |
| Cooperative compliance approach exists for -Large taxpayers | 2024 | 1 |
| Cooperative compliance approach exists for -HNWI taxpayers | 2024 | 0 |
| Cooperative compliance approach exists for -Other taxpayers | 2024 | 1 |
| Most employees that have tax deducted through direct withholding required to file a return | 2024 | 1 |
| Administration receives data from devices that register transactions | 2024 | 1 |
| Administration uses electronic compliance checks as part of returns filing process | 2024 | 1 |
| Administration has specialized audit staff for international tax issues | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Customs data | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data from stock exchanges | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data from the Social Security Agency | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Data from online (internet-based) vendors | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data from Utilities | 2022 | 1 |
| Administration checks the quality of data reported by third parties on a systematic basis | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data on property ownership and sales | 2022 | 1 |
| Administration undertakes fully automated compliance checks based on data matching/analysis | 2022 | 1 |
| Administration undertakes fully automated compliance checks - compliance issues automatically communicated to taxpayer | 2022 | 0 |
| Administration measures the effectiveness of any compliance interventions undertaken | 2022 | 1 |
| Administration has standards for auditor productivity | 2022 | 1 |