Nigeria Tax Advisory for International and Cross-Border Groups

Strategic, defensible tax advice for global companies operating in or investing into Nigeria, delivered by specialists who understand both Nigerian legislation and complex multinational structures.

  • Corporate tax and international structuring
  • Cross-border tax reviews and planning
  • On-the-ground insight for global finance teams

Nigeria has introduced sweeping changes to its tax laws, coming into effect from 2026, and we have analysed these developments extensively. The reforms touch every major area of the system: corporate income tax, tax on capital gains, VAT, stamp duties and tax incentives. With new definitions of “resident” for both individuals and companies, the introduction of Controlled Foreign Company rules, top-up taxes and revised capital gains provisions, the impact on cross-border structures is particularly significant for both inbound and outbound investment.

For multinational and pan-African groups, these changes heighten the need for clear, defensible structures, accurate residency and PE assessments, well-governed intercompany arrangements and forward-looking tax planning. We help you understand your exposure, strengthen your Nigerian and global tax position and ensure your group is ready for the new environment.

What we offer

Clarity for multinational structures

Guidance that connects Nigerian rules with global group policies, intercompany arrangements and reporting obligations.

Robust documentation and evidence

Support that ensures your tax position withstands scrutiny from Nigerian and foreign tax authorities.

Commercial answers, not theory

Advice that reflects how international groups actually operate, from headquarters through to Nigerian subsidiaries.

Our Nigerian tax services for multinationals

Free checklist

Everything you need to prepare for the 2026 Nigerian tax changes

Our team has developed a practical checklist covering the key steps for businesses, foreign companies linked to Nigeria and multinationals. It includes actions such as VAT system updates, residency and CFC assessments, top-up tax exposure, payroll changes and Free Zone planning. This is based directly on our Nigerian Tax Law Reform explainer and action guide.

Ideal for CFOs, finance teams and tax managers planning their 2026 roadmap.

Why Regan van Rooy?

We specialise in cross-border tax for African and international groups, with teams working across South Africa, Mauritius, Ireland and the wider region. Our advisers bring Big Four leadership experience, extensive African tax knowledge and practical insight into how multinational structures interact with Nigerian rules.

You get strategic advice grounded in real operational complexity.

Russell Eastaugh

African Tax Lead

Ex-Big Four, expert in African corporate tax, cross-border structuring and multinational advisory.

Russell is a Fellow of the Chartered Institute of Taxation of Nigeria and a member of the previous Nigerian government’s Fiscal Policy Reform Committee. This extensive experience provides deep insight into previous attempts to reform and improve the Nigerian tax system.

Caoilfhionn van der Walt

Founder & Managing Partner

Ex-Deloitte London

International tax adviser with extensive Big Four and global structuring experience.



Latest insights on African and Nigerian tax

Watch our latest webinars

Playlist

5 Videos

Book a consultation

Get tailored advice for your Nigerian entities, cross-border arrangements and global tax position.

Thank you for your interest, please complete the form below to download the checklist pdf.

Loading...

Complete the fields below to download the guide by Dr Daniel N Erasmus.

Loading...

Book a meeting with our Transfer Pricing team by completing the form below.

Loading...

Thank you for your interest, please complete the form below to download the full pdf.

Loading...