Companies planning mergers, acquisitions, or corporate restructuring will have to pay closer attention to how they structure transactions as Nigeria’s tax reform creates different tax outcomes for different deal structures.
Yvonne Afolabi, a transfer pricing expert, said the increase in capital gains tax (CGT) from 10 percent to 30 percent makes taxable disposals and certain outright asset sales more expensive, while qualifying mergers and restructurings can benefit from tax relief.
“In practice, this could encourage companies to consider restructuring options more carefully rather than automatically pursuing an outright disposal,” Afolabi said.
The Nigeria Tax Act 2025, which took effect on January 1, 2026, brought capital gains into the corporate income tax framework, meaning assessable gains from the disposal of chargeable assets, including shares, are now taxed at the applicable 30 percent rate.
However, the treatment differs depending on how a transaction is structured.
