Tax & Business Matters - Nigeria

Nigeria and Ghana have concluded a double taxation (avoidance) treaty

Nigeria and Ghana have signed an agreement for the avoidance of double taxation between the two countries. The negotiation process was concluded on Thursday 26 July 2018. The agreement will be signed by the competent authorities of both countries at a future date.

Once signed, the agreement will then be presented to the National Assembly for ratification in order to give it the force of the law in Nigeria. South Africa is currently the only country with an in-force double taxation treaty with Nigeria.

More details to be provided later.

Mauritius is changing its tax rules in a significant way

Significant tax reforms have been introduced in the Global Business sector in Mauritius. The key highlights are listed below​:

Category 1
Global Business License

• Effective from 1 January 2019, the Deemed Foreign Tax Credit (“DFTC”) regime will be abolished and GBL companies will be taxed at the rate of 15%
• Introduction of an 80% Partial Exemption Regime on certain income streams, subject to pre-defined substance requirements
• Existing GBC1 companies, where licenses were issued on or before 16 October 2017, will be grandfathered until 30 June 2021. Licenses issued after 16 October 2017 will be grandfathered until 31 December 2018

Category 2
Global Business License

• Effective from 1 January 2019, the Category 2 Global Business Licence (“GBC2”) will be abolished
• Existing GBC2 companies, where licenses were issued on or before 16 October 2017, will be grandfathered until 30 June 2021. Licenses issued after 16 October 2017 will be grandfathered until 31 December 2018.
• After 31 December 2018 or 30 June 2021 as applicable, GBC2 licences will lapse and companies will need to comply with the prescribed requirements of the GBL as issued by the FSC.

Read further details in the link below. You can also reserve a space at the live webcast by PwC Mauritius as outlined below:

Tax Alert and Live Webex

Live Webex Tax reform in the Global Business sector in Mauritius

The measures announced in the Budget 2018-19 regarding the Global Business Sector have now been reflected in the Finance Bill 2018. To discover the major changes, join our Live Webex (incl. Q&A) on Friday 27 July 2018 at 10am, New York, GMT -04:00 6pm, Mauritius, GMT +04:00 7:30pm, Mumbai, GMT +05:30

The Tax Appeal Tribunal has been reconstituted

The Tax Appeal Tribunal (TAT) is an administrative body established by the Federal Inland Revenue Service Establishment Act to hear and resolve tax disputes arising from all federal tax legislation. These include, the Companies Income Tax Act, Personal Income Tax Act, Petroleum Profits Tax Act, Value Added Tax Act, Capital Gains Tax Act, Stamp Duties Act, Tax and Levies (Approved List for Collection) Act, all regulations or rules issued in terms of these legislation and any other laws subsequently passed by the National Assembly.

The Tribunal is the first forum for aggrieved persons (taxpayers or tax authorities) to litigate before approaching the High Court.

Read our alert for details:

Download PwC Tax Alert_FGN Reconstitutes TAT_July2018

FIRS Issues CbCR Guidelines

Following the introduction of Nigeria's Country-by-Country (CbC) Reporting Regulations on 19 June 2018, the Federal Inland Revenue Service (FIRS) today released the detailed Guidelines for CbC Reporting in Nigeria.

 

 

In addition to the Guidelines, the FIRS also released the following documents:

1. Yearly CbC notification form; and 
2. Guidelines on the appropriate use of CbC report.

You can access the documents here and read our alert below for further details:

 

Download PwC Tax Alert_Nigeria Issues CbyCR Guidelines_July2018

 

Nigeria: Changes to the Visa on Arrival Process

Visitors arriving Nigeria on the Visa on Arrival (VoA) programme will no longer be able to make cash payments​. V​oA fees ​are now to be ​paid ​using ​electronic cards at the ports of entry or online via the Nigeria Immigration Service ​(NIS) ​website.​ ​

Plans to upgrade the VoA service to include biometric solutions at the Murtala Muhammed International Airport, Lagos, have been suspended​ due to controversies regarding the applicable fees and procedures. The biometric service is intended to allow government securely link a person to a single identity and provide clear evidence of the holder’s immigration status.

The Nigeria Immigration Service (​NIS) has ​confirmed that ​VoAs will continue to be issued under the standard process pending the implementation of the biometric service​. Travelers are advised to take note of the current requirements and plan for the future additional cost of the biometric enrollment process as well as additional time that may be required at the ports of entry​ when the service is fully implemented.