Corporate Taxation Amendments in the Nigeria Finance Act 2022: What Businesses Need to Know.

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The Nigeria Finance Act 2022 introduces significant amendments to the corporate taxation landscape, which businesses must be well-informed about to navigate the changing regulatory landscape effectively. As a reputable accounting firm in Nigeria, we understand the critical role of corporate taxation in driving economic growth and fostering a conducive business environment. In this article, we provided an overview of the key corporate taxation amendments in the Act and their implications for businesses operating in Nigeria.

  • Group Consolidated Relief (GCR) System:

One of the fundamental changes introduced by the Nigeria Finance Act 2022 is the implementation of the Group Consolidated Relief (GCR) system. The GCR allows eligible companies within a group to offset their losses against the profits of other group entities. This consolidation of losses can lead to substantial tax savings for the group as a whole, promoting collaboration and efficiency among related entities.

Implication: Businesses with subsidiaries or associated companies should assess their eligibility for GCR and consider optimizing their group structures to capitalize on the potential tax benefits.

  • Thin Capitalization Rules:

The Act amends the Thin Capitalization rules, which impact the deductibility of interest on loans obtained from related parties. Under the new provisions, businesses must adhere to the prescribed debt-to-equity ratios to ensure that the interest on related-party loans remains fully deductible for tax purposes.

Implication: Companies with related-party loans need to review their capital structures to comply with the revised Thin Capitalization rules and avoid potential restrictions on interest deductions.

  • Digital Services Tax (DST):

In response to the digitalization of the economy, the Nigeria Finance Act 2022 introduces the Digital Services Tax (DST). The DST targets non-resident companies that provide digital services to Nigerian customers. These services may include online advertising, software subscriptions, and other digital transactions. The DST is set at a specific percentage of the company’s revenue from qualifying digital services.

Implication: Foreign businesses providing digital services to Nigerian customers should evaluate their revenue streams to determine their DST liabilities and ensure compliance with the new taxation rules.

  • Exempting Small Companies from Minimum Tax:

The Act exempts small companies with an annual turnover of 25 million Naira or less from the minimum tax provision. This measure is aimed at providing relief to small businesses and startups, encouraging their growth and contributing to economic diversification.

Implication: Small companies with turnover within the threshold can enjoy relief from the minimum tax, reducing their tax liabilities and supporting their business operations.

  • Taxation of Real Estate Investment Trusts (REITs):

The Nigeria Finance Act 2022 provides clarity on the taxation of Real Estate Investment Trusts (REITs). It confirms that rental income earned by REITs from real estate activities will be exempt from corporate income tax at the company level, provided that the income is distributed to unit holders.

Implication: REITs and potential investors should be aware of the clarified tax treatment, making REITs an attractive investment option in the real estate sector.


The Nigeria Finance Act 2022 brings substantial amendments to corporate taxation, reflecting the government’s commitment to enhancing the business environment and fostering economic growth. The introduction of the Group Consolidated Relief (GCR) system, amendments to Thin Capitalization rules, and the implementation of the Digital Services Tax (DST) demonstrate the government’s response to the evolving business landscape, especially with the digitalization of the economy.

As a trusted accounting firm, we advise businesses to proactively understand the implications of these amendments on their tax positions and compliance requirements. By staying informed and seeking professional guidance, businesses can navigate the complexities of the Act, optimize their tax planning, and position themselves for success in Nigeria’s dynamic corporate taxation landscape.

For professional advice on Accountancy, Transfer Pricing, Tax, Assurance, Outsourcing, online accounting support, Company Registration, and CAC matters, please contact Sunmola David & CO (Chartered Accountants & Tax Practitioners) at Lagos, Ogun state Nigeria offices, You can also reach us via WhatsApp at +2348038460036.