As part of Olaniwun Ajayi LP’s ‘Deconstructing the Tax Reform Acts’ Series, this article is focused on taxes imposed on Non-Resident Companies (Including Persons Engaged in Shipping and Air Transport Business) under the Tax Reform Acts. It offers a detailed analysis of the significant changes introduced by the Nigeria Tax Act, 2025 and the Nigeria Tax Administration Act, 2025 concerning the taxation of foreign entities operating in Nigeria.
The Article explores, among other provisions of the Acts, the redefined concept of Permanent Establishment (PE) and Significant Economic Presence (SEP), the updated compliance obligations, and the widened tax net applicable to various cross-border transactions. Special attention is also given to the new compliance framework for shipping and air transport businesses, alongside implications for enforcement and risk management.
