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Nigeria VAT non-resident digital services; goods obligations delayed

Simplified VAT compliance for foreign e-services and goods sellers & marketplaces

Nigeria’s Federal Inland Revenue Service (FIRS) has delayed start date for non-resident businesses to register for the supplies of e-commerce goods through digital platforms. The plan had been a 1 January 2024 start date. No new date has been confirmed.

It imposed the same obligation on foreign suppliers of digital services in January 2022. This included simplified compliance procedures for non-resident providers.

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Nigeria had already introduced VAT on B2C sales in February 2020. But this has now been extended: sales to Nigerian consumers must include local VAT, requiring a VAT registration with FIRS; B2B sales will require the Nigerian customer to withhold the VAT and pay directly to FIRS. Therefore if the provider is only making B2B sales, then it will not have to VAT register.

What digital services and physical goods liable to Nigerian VAT?

FIRS makes the following definitions:

  • supplies, through digital means, of goods, services, intangibles and other digital products by persons not physically present, located or represented in Nigeria
  • It covers both B2B and B2C

Marketplace liabilities

In addition to the underlying suppliers, marketplaces and similar intermediaries may be held responsible for the VAT liabilities. This would require them to VAT register, collect and remit the taxes from Nigerian customers.

Invoicing obligations

Nigeria expects VAT registered business to issue compliant electronic invoices – note an application may be made for delaying this obligation – which should include the following:

  • Name and TIN of the supplier
  • Description of the goods or digital services
  • Date
  • Value
  • VAT liability

VAT registration threshold

There is a $25,000 VAT registration threshold after which a foreign providers must register immediately in the case of B2C sales. There is no simplified VAT registration process or reduced VAT return set until 2022. They may apply for a Tax Identification Number (TIN) from FIRS. They may choose to appoint a local VAT agent if they wish to assist with reporting and compliance.

Once registered, returns are expected to be filed on a monthly basis. They are due, along with VAT payment, by the 21st of the month following.

VAT Calc’s VAT Filer can accurately populate Nigerian or other country VAT return with verified data from our VAT Calculator or VAT Auditor services

Determining if Nigerian VAT is due

Any provider or liable intermediary must establish if the place of consumption is Nigeria, and VAT therefore due. They may reply on the following:

  • Customer billing address
  • Customer incorporated in Nigeria
  • Nigerian IP address
  • Any other similar evidence

Digital services subject to Nigerian VAT

Services covered include any intangible or services delivered via electronic or digital means or similar networks, whose supply is essentially automated, involves minimal human intervention, and is impossible to ensure in the absence of information technology. This excludes broadcast and telecommunications services.

Services covered shall include but not limited to:

  • Streaming, downloading or access to digital content including movies, music, e-books, magazines, news, applications, games, library services or like services;
  • Online gaming;
  • Online ticketing excluding international air travels and freight charges;
  • Online betting services;
  • Online intermediation platform services, including online marketplaces, payment platforms, ride hailing, travel and accommodation booking, rental services or like services;
  • Online advertising services;
  • Subscription based social media platforms including video conferencing applications, instant messaging, chat, dating, image/video sharing or like services;
  • Standardised online education services such as e-learning, webinars or like services;
  • Cloud computing services including cloud storage services;
  • Auction services;
  • Automated online professional and consultancy services
  • Online stores; and
  • E-library.

Africa & Middle East VAT on digital services

Comments (click for details) Rate Date Threshold Comments
Algeria 9% Jan 2020 Nil
Angola 14% Oct 2019
Bahrain 10% Jan 2019 Nil
Benin 18% Oct 2023 TBC
Botswana 14% 2024 - Pending implementation
Cameroon 19.5% Jan 2020 XAF 50 million
Cape Verde 15% Jan 2022 Nil
Congo, Democratic Republic 16% Jan 2024 -
Egypt 14% Sep 2016 EGP 500,000
Ghana 12.5% Apr 2022 GHS 200,000
Guinea 18% Jan 2016 Nil
Israel 17% TBC Proposals withdrawn
Ivory Coast 18% 2022 -
Jordan 16% JOD 30,000
Kenya 16% Sep 2013 - Registration threshold removed 2023
Kuwait 5% Jan 2024? - TBC
Madagascar 20% Nil Collections via fiscal rep
Mauritius 15% 2020
Morocco 20% 2024
Mozambique 16% 2017 Nil
Nigeria 7.5% Jan 2020 $25,000
Oman 5% Apr 2021 OMR 35,000
Rwanda 18% TBC
Saudi Arabia 15% Jan 2018 Nil
Senegal 18% Jul 2024 Nil Fiscal representative required
Sierra Leone 15% Jan 2021 SLE 100,000 No non-resident rules
South Africa 15% Jun 2014 ZAR 1 million
Tanzania 18% Jul 2022 Nil Residents since Jul 2015
Tunisia 19% Jan 2020 Nil Withholding VAT; 3% Royalty Tax
Uganda 18% Jan 2020 UGX 150m
United Arab Emirates 5% Jan 2018 AED 375,000
Zambia 16% Jan 2024 Fiscal Representative req'd
Zimbabwe 14.5% Jan 2020 Nil


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