One of the ways through which the Nigeria Tax Act, 2025 (the “NTA”) works towards creating a more efficient tax system is by clarifying the tax obligations on non resident individuals (“NRIs”) employed by Nigerian residents.
Previously, under section 10 of the now-repealed Personal Income Tax Act, 2004 (as amended) (“PITA”), employment income for work wholly or partly performed in Nigeria was deemed to be liable to tax in Nigeria. Under this provision, foreigners employed by Nigerian residents or employers with fixed bases in Nigeria were liable to personal income tax on that salary, regardless of whether they were physically
present in Nigeria or not. Contemporary tax legislations, particularly the NTA, now seek to distinguish between employment services performed physically in Nigeria and those performed remotely
