Non-resident digital suppliers face uncertainty over Nigeria’s e-invoicing – Report – Daily Trust

Non-resident digital service suppliers working in Nigeria face uncertainty over compliance with the nation’s digital invoicing regime, regardless of being required to register for Value Added Tax (VAT), cost clients and remit collections to the Nigeria Revenue Service (NRS), in keeping with a report by PwC.

The report titled, “VAT in Africa: Digital Services 2026”, mentioned though Nigeria’s tax legal guidelines and coverage framework counsel that Non-Resident Taxable Suppliers (NRTSs) fall inside the scope of the e-invoicing regime, the income authority had but to obviously outline the operational necessities relevant to such entities.

Daily Trust studies that the non-resident digital suppliers are international firms—equivalent to streaming platforms, cloud computing companies, app shops, and on-line advertisers—that promote digital services or products to native customers with out having a bodily workplace or everlasting institution in that nation. 

These firms are required to register for and gather Value Added Tax (VAT) on cross-border transactions to stage the taking part in subject with native companies.

In the newly launched report, PwC famous that the uncertainty persevered as of February 2026, when the NRS restricted necessary e-invoicing compliance to giant taxpayers with annual turnover of N5bn and above.

The report mentioned the NRS had not expressly excluded non-resident suppliers from the class, elevating the likelihood that multinational digital companies assembly the turnover threshold may technically be lined by the requirement.

It, nevertheless, suggested affected firms to arrange for potential implementation whereas searching for formal clarification from the tax authority.

“In light of this uncertainty, NRTSs should proactively prepare for potential implementation,” PwC mentioned, including that such preparation would place the businesses for compliance if the NRS confirms their inclusion and proceeds with enforcement.

The agency additionally beneficial that non-resident suppliers formally interact the NRS to acquire written affirmation that they weren’t at present required to adjust to the e-invoicing mandate and wouldn’t face penalties for non-compliance throughout the interval of uncertainty.

The growth comes amid Nigeria’s broader tax reforms, which have strengthened the framework for taxing cross-border digital transactions and imposed direct VAT obligations on international suppliers serving Nigerian clients.

Daily Trust studies that underneath Section 150 of the Nigeria Tax Act (NTA), non-resident taxable suppliers offering taxable items and companies to Nigerian clients, together with companies and particular person customers, are required to adjust to relevant VAT guidelines.

The NTA additionally empowers the NRS to concern tips on the shape, timing and procedures for returns and funds by non-resident suppliers appointed by the service.

PwC mentioned the NRS’s Simplified Compliance Regime for VAT, which took impact on January 1, 2022, remained related pending the issuance of an up to date round reflecting the provisions of the brand new tax laws.

Under the regime, non-resident suppliers offering items, companies, intangible property and different digital merchandise to Nigerian clients by digital means should register for VAT, receive a Tax Identification Number (TIN), cost VAT on their invoices and remit the collections to the NRS.

The customary VAT charge is 7.5 per cent, whereas suppliers are typically required to register when their annual provides to Nigerian clients attain or exceed $25,000, or its equal in different currencies.

Registered suppliers should gather VAT and remit it to the NRS earlier than the twenty first day of the next month. Payments are made within the forex of the transaction.

The obligations cowl a variety of digital companies, together with streaming and downloadable content material, on-line gaming, betting, promoting, cloud computing, on-line marketplaces, ride-hailing, journey and lodging bookings, subscription-based social media, digital studying and automatic skilled companies.

Online ticketing, digital libraries and on-line shops are additionally among the many companies recognized within the report.

PwC defined that the place a international provider fails to cost VAT on a taxable business-to-business transaction, the Nigerian buyer is required to self-account for the tax and remit it to the NRS.

However, it famous that gathering VAT on business-to-consumer transactions might be harder the place the non-resident provider did not cost the tax.

The report additionally highlighted provisions permitting non-resident suppliers to assert enter VAT incurred on companies and stuck property used to make taxable provides in Nigeria.

Under Section 155(4) of the NTA, eligible enter VAT might be offset in opposition to output VAT collected, with solely the online quantity remitted to the income service.

Where enter VAT exceeds output VAT, suppliers might carry ahead the surplus as a credit score or apply for a refund, topic to the relevant statutory circumstances and timelines.

PwC mentioned the NRS was required to course of legitimate VAT refund requests inside 30 days. Refund claims have to be submitted inside 12 months of the transaction that gave rise to the surplus credit score.

Beyond VAT, the report recognized further tax concerns for non-resident suppliers, significantly these working middleman platforms.

Such platforms are required to fulfil VAT registration, invoicing and submitting obligations for gross sales accomplished by them, as if they have been the precise suppliers. They should additionally preserve data of transactions involving Nigerian clients.

Although non-resident suppliers might appoint representatives to deal with sure administrative obligations in Nigeria, PwC harassed that the appointment doesn’t switch their final tax legal responsibility. The suppliers should nonetheless register in their very own names and stay accountable for assembly their obligations.

The agency additionally famous that non-resident suppliers primarily based in nations with out relevant tax treaties might be liable to Nigerian firm earnings tax on earnings sourced from the nation.

Such firms are required to file earnings tax returns inside six months of the tip of their accounting 12 months, with penalties and curiosity relevant for defaults.