908. Nigeria can legally issue the following four types of rulings within the scope of the transparency framework: (i) preferential regimes;1 (ii) rulings providing for unilateral downward adjustments; (iii) permanent establishment rulings; and (iv) related party conduit rulings.

909. For Nigeria, past rulings are any tax rulings within scope that are issued either (i) on or after 1 January 2015 but before 1 April 2017; and (ii) on or after 1 January 2012 but before 1 January 2015, provided they were still in effect as at 1 January 2015.

910. Nigeria confirms that no past rulings have been issued, as its administrative framework for issuing rulings only took effect at a later stage. Therefore, no recommendations are made regarding past rulings.

911. For Nigeria, future rulings are any tax rulings within scope that are issued on or after 1 April 2017.

912. Nigeria indicates that there are not yet processes in place to ensure the implementation of the obligations relating to the transparency framework.

913. Nigeria did not yet have a review and supervision mechanism under the transparency framework for the year in review.

914. Nigeria is recommended to ensure that it has put in place an effective information gathering process to identify all relevant future rulings and all potential exchange jurisdictions and to implement a review and supervision mechanism, as soon as possible (ToR I.A).

915. Nigeria has the necessary domestic legal basis to exchange information spontaneously. Nigeria notes that there are no legal or practical impediments that prevent the spontaneous exchange of information on rulings as contemplated in the Action 5 minimum standard.

916. Nigeria has international agreements permitting spontaneous exchange of information, including: (i) the Multilateral Convention on Mutual Administrative Assistance in Tax Matters: Amended by the 2010 Protocol (OECD/Council of Europe, 2011[1]) (“the Convention”) and (ii) bilateral agreements in force with 14 jurisdictions.2

917. Nigeria does not yet have a process to complete the templates on all relevant rulings, to make them available to the Competent Authority for exchange of information, and to exchange them with relevant jurisdictions.

918. During the year in review, no exchanges took place and no data on the timeliness of exchanges is reported.

919. Nigeria is recommended to develop a process to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur in accordance with the form and timelines under the transparency framework going forward (ToR II.B).

920. As there was no information on rulings exchanged by Nigeria for the year in review, no statistics can be reported.

921. Nigeria does not offer an intellectual property regime for which transparency requirements under the Action 5 Report (OECD, 2015[2]) were imposed.


[3] OECD (2021), BEPS Action 5 on Harmful Tax Practices - Terms of Reference and Methodology for the Conduct of the Peer Reviews of the Action 5 Transparency Framework, OECD Publishing, Paris,

[2] OECD (2015), Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance, Action 5 - 2015 Final Report, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris,

[1] OECD/Council of Europe (2011), The Multilateral Convention on Mutual Administrative Assistance in Tax Matters: Amended by the 2010 Protocol, OECD Publishing, Paris,


← 1. Free trade zones.

← 2. Participating jurisdictions to the Convention are available here: Nigeria also has a bilateral agreement with Belgium, Canada, China (People’s Republic of), Czech Republic, France, Netherlands, Pakistan, Philippines, Romania, Slovak Republic, Spain, Singapore, South Africa, and United Kingdom.

Metadata, Legal and Rights

This document, as well as any data and map included herein, are without prejudice to the status of or sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Extracts from publications may be subject to additional disclaimers, which are set out in the complete version of the publication, available at the link provided.

© OECD 2022

The use of this work, whether digital or print, is governed by the Terms and Conditions to be found at