Foreign firms providing consulting, technical, and other remote services to Nigerian clients are reassessing their structures. The trigger: Nigeria’s new Tax Act (NTA) 2025 has narrowed the circumstances under which remote services create a taxable presence in the country.
The shift centres on the treatment of Technical, Professional, Management and Consultancy (TPMC) services under Nigeria’s Significant Economic Presence (SEP) rules.
Under Paragraph 2 of the Significant Economic Presence Order 2020, remote TPMC services provided to Nigerian clients automatically created SEP exposure for non-resident companies. However, that provision was deleted under Section 197(d) of the Nigeria Tax Act 2025.
According to Sulaiman Ishaq Olamide, a tax consultant, the implication is that “mere provision of TPMC services may no longer create SEP exposure for non-resident persons in Nigeria.”
He explained that foreign companies providing such services may now only be subject to withholding tax as final tax unless they create a separate Significant Economic Presence or Permanent Establishment in Nigeria, subject to applicable Double Tax Agreements.
