Nigeria’s New Tax Act 2025: Controlled Foreign Companies Explained | Russell Eastaugh | Ep 4
Автор: Regan van Rooy
Загружено: 2025-08-20
Просмотров: 57
In this episode, Russell Eastaugh, Head of African Tax Advisory at Regan van Rooy, breaks down another significant update in the Nigerian Tax Act and Tax Administration Act 2025 - the new Controlled Foreign Companies (CFC) rules and what they mean for businesses with cross-border structures.
Key Highlights:
Deemed Dividends: If a foreign company controlled by a Nigerian company does not distribute profits, those profits may be deemed distributed and taxed in Nigeria.
30% Control Threshold: Holding as little as 30% of voting rights, dividends, or capital can trigger CFC provisions – a much lower bar than many expected.
Tax Residency Still Matters: Even if not caught by CFC rules, a foreign company could still be considered Nigerian tax resident if its place of effective management is in Nigeria.
What this means: These changes significantly tighten Nigeria’s grip on offshore profits. Multinationals and Nigerian groups with foreign subsidiaries need to reassess their structures and prepare for possible tax exposure under the new rules.
In the final episode of this series, Russell will be joined by Caoilfhionn van der Walt, Founder & Managing Partner at Regan van Rooy, to discuss the full scope of the Nigerian Tax Law Reform 2025 and what businesses should be doing now.
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