Nigerian Tax Residency When You Move Abroad (2026)
Key takeaways
- New law from 1 January 2026: the Nigeria Tax Act 2025 replaces the Personal Income Tax Act, and the Nigeria Revenue Service replaces FIRS.
- Residents are taxed on worldwide income; non-residents only on Nigerian-source income (PwC, Nigeria — Residence).
- The 183-day test is only one trigger. A permanent home, habitual abode, or substantial economic/family ties can each make you resident regardless of days.
- To be treated as non-resident you must fail all the residence tests at once, so quality of connection now matters, not just day-count.
- New personal income tax bands: the first ₦800,000 is tax-free; the top rate rises to 25%.
- Individuals are generally assessed by the State Internal Revenue Service of their state of residence; the NRS handles federal and non-resident matters.
Nigeria’s 2025–2026 tax reform in brief
Nigeria has overhauled its tax system. Four reform laws signed in 2025 take effect on 1 January 2026: the Nigeria Tax Act 2025 (the consolidated charging law), the Nigeria Tax Administration Act 2025, the Nigeria Revenue Service (Establishment) Act 2025, and the Joint Revenue Board (Establishment) Act 2025. The Nigeria Revenue Service (Establishment) Act repeals the old FIRS (Establishment) Act 2007 and renames the Federal Inland Revenue Service as the Nigeria Revenue Service (NRS), which went live on 1 January 2026 (KPMG, The NRS (Establishment) Act 2025). For individuals leaving Nigeria, the headline is that residency now determines the scope of what Nigeria can tax, and the residency test has been tightened.
Who counts as a Nigerian tax resident?
Under the new rules an individual is resident in Nigeria in a year of assessment if any one of the following applies: they are domiciled in Nigeria; they have a permanent place available for their domestic use in Nigeria; they have a place of habitual abode in Nigeria; they have substantial economic and immediate family ties in Nigeria; they are present in Nigeria for an aggregate of 183 days or more in any 12-month period (including annual leave and temporary absences); or they serve as a Nigerian diplomat abroad (PwC — Nigeria, Residence). The 183 days need not be consecutive; separate visits are added together across the 12-month window.
Why the 183-day test is not the whole story
The most important change for emigrants is that you can spend well under 183 days in Nigeria and still be treated as resident. To be a non-resident individual you must satisfy every negative condition at the same time: not domiciled in Nigeria, no permanent home available for your use, no habitual abode, no substantial economic and immediate family ties, present for fewer than 183 days, and not a Nigerian diplomat. Because all conditions must be met together, commentators have observed that very few people now qualify as genuine non-residents, one analysis is bluntly titled “Who Is A Non-Resident Individual Now? – Almost No One” (Mondaq, 2025). In practice, if you keep a house standing ready for you in Lagos, run an active business in Nigeria, or leave your spouse and children living there, Nigeria may still regard you as resident even after you have physically moved.
Worldwide income versus Nigerian-source income
The consequence of your status is significant. A Nigerian tax resident is liable to tax on worldwide income, income, gains or profits are deemed Nigerian and taxed in Nigeria irrespective of where they arise. A non-resident is taxed only on Nigerian-source income (PwC — Significant developments). So once you become genuinely non-resident, your foreign salary and foreign investment income fall outside the Nigerian net, but income arising in Nigeria, such as rent from a Nigerian property, profits from a Nigerian business, or pay for duties performed in Nigeria, remains taxable in Nigeria. Employment income is generally sourced to Nigeria where the duties are performed in Nigeria or the employee is resident, unless it has already been taxed in your country of tax residence under a double-tax treaty.
The new personal income tax bands
The Nigeria Tax Act 2025 introduces a revised progressive scale for chargeable income, effective 1 January 2026: the first ₦800,000 is taxed at 0%; the next ₦2,200,000 at 15%; the next ₦9,000,000 at 18%; the next ₦13,000,000 at 21%; the next ₦25,000,000 at 23%; and any amount above ₦50,000,000 at 25% (PwC — Significant developments). The old Consolidated Relief Allowance is gone, replaced by a rent relief of 20% of annual rent paid, capped at ₦500,000. Capital gains are now taxed at personal income tax rates, and the exemption threshold for compensation for loss of office has risen from ₦10 million to ₦50 million, useful to know if you receive a severance package on leaving a Nigerian employer.
Which authority assesses you, and where
For individuals, personal income tax in Nigeria is generally administered by the State Internal Revenue Service of the state where you are resident, while the federal Nigeria Revenue Service handles corporate taxes, residents of the Federal Capital Territory, members of the armed forces and police, foreign service officers, and non-resident individuals with Nigerian-source income. When you leave and cease to be resident in any Nigerian state, your ongoing Nigerian-source income can fall to the NRS. The reforms also create a Joint Revenue Board to coordinate federal and state administration and reduce double assessment. Practically, keep your Tax Identification Number active and make sure you know which office holds your file before you go.
Planning your exit year
The year you leave is usually split between resident and non-resident periods, so keep a careful record of your travel dates, annual leave and temporary returns, because days count toward the 183-day test. Break your Nigerian ties deliberately if you intend to be non-resident: give up a permanent home kept solely for you, wind down or restructure Nigerian economic interests, and be aware that leaving close family behind can preserve residency. File any final Nigerian return that is due and settle outstanding liabilities. Where you become tax resident in another country, check whether Nigeria has a double-tax treaty with it to avoid being taxed twice on the same income. None of this is a substitute for advice, confirm your position with the Nigeria Revenue Service, your State Internal Revenue Service, or a qualified tax adviser.
How Flyto can help
Flyto moves households from Nigeria to Europe and worldwide, door-to-door; get a quote. We manage the logistics of your relocation so you have time to get your tax residency and financial affairs properly documented before you go.
Frequently asked questions
If I move abroad, do I still pay Nigerian tax on my foreign salary?
Only if you remain a Nigerian tax resident. Residents are taxed on worldwide income; genuine non-residents are taxed only on Nigerian-source income (PwC).
Is spending under 183 days in Nigeria enough to become non-resident?
Not on its own. You must also give up your permanent home, habitual abode and substantial economic and family ties in Nigeria; all the non-residence conditions must be met together (PwC — Residence).
Is FIRS still the tax authority?
No. From 1 January 2026 the Federal Inland Revenue Service became the Nigeria Revenue Service under the NRS (Establishment) Act 2025 (Nigeria Revenue Service).
What are the new personal income tax rates?
The first ₦800,000 is tax-free, then rates run 15%, 18%, 21%, 23% and 25% through rising bands, with a top rate of 25% (PwC — Significant developments).
Will rent from my Nigerian property still be taxed after I leave?
Yes. Rent from Nigerian property is Nigerian-source income and remains taxable in Nigeria whether or not you are resident (PwC).
Who assesses my personal income tax?
Generally the State Internal Revenue Service of your state of residence; the federal NRS handles FCT residents, certain federal categories and non-residents with Nigerian income (Nigeria Revenue Service).
Sources
- Nigeria Revenue Service (NRS) — official site
- PwC Worldwide Tax Summaries — Nigeria, Individual Residence
- PwC Worldwide Tax Summaries — Nigeria, Significant Developments
- KPMG — The Nigeria Revenue Service (Establishment) Act 2025
- Mondaq — Who Is A “Non-Resident Individual” Now?
- Mondaq — Individual Tax Residency Under the Tax Reform Acts
- Nigeria Tax Act 2025 (full text)
- Baker Tilly Nigeria — 2025 Tax Reform Acts Explained