Nigeria has raised its corporate capital gains tax to 30% and introduced new rules for taxing indirect asset transfers, according to a report by PwC Nigeria.
Key facts
- •Nigeria's corporate capital gains tax rate is now 30%, compared to 25% in Ghana and 21.6% in South Africa.
- •The new tax rules apply to assets including equities, properties, and digital assets.
- •The Senate Committee on capital market previously reported that N2 trillion was wiped out from the capital market during debates over the CGT.
- •PwC noted that the interaction between indirect transfer provisions could lead to varying interpretations regarding when the 50% value threshold applies.
- •The NTA does not explicitly state whether companies can deduct capital losses against capital gains.
Nigeria has introduced a new 30% capital gains tax (CGT) rate for companies, marking a significant increase from the previous 10% rate. The change, part of the Nigeria Tax Act (NTA) that took effect on January 1, 2026, also expands the government's authority to tax offshore transactions involving Nigerian assets. A report by PwC Nigeria highlights that these reforms position the country with the highest headline corporate capital gains tax rate among several major African economies.
By the numbers
Expanded Taxing Rights on Indirect Transfers
The new regime allows Nigeria to tax gains from the disposal of assets by non-residents even if the transaction occurs outside the country. Under Section 46(f) of the NTA, foreign entities may be deemed to have Nigerian assets if more than 50% of their value is derived from such assets within 365 days of disposal. Additionally, Section 47 permits taxation if a transaction results in a change of ownership or interest in a Nigerian company or asset, regardless of the foreign entity's asset value composition.
Unresolved Technical and Administrative Challenges
PwC identified several areas of uncertainty within the new laws, including the treatment of capital losses for companies and whether capital gains are subject to the Development Levy. The report also noted a lack of statutory guidance regarding valuation methodologies for unlisted companies and the absence of clear rules for identifying the cost base of shares acquired at different prices. Investors are expected to face increased compliance costs as they navigate these technical ambiguities.
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This article was independently rewritten by ManyPress editorial AI from reporting originally published by AllAfrica.
