Impact of Nigeria Finance Act 2023 on Cross-Border Transactions


Cross-border transactions play a vital role in Nigeria’s economy, fostering international trade, investment, and economic growth. The Nigeria Finance Act 2023 introduces significant changes to the taxation of cross-border transactions, aiming to enhance transparency, promote tax compliance, and strengthen Nigeria’s position in the global market. As a reputable accounting firm in Nigeria, we explore the key provisions in the Finance Act 2023 that impact cross-border transactions and provide insights into the implications for businesses engaged in international trade and investment.

1. Transfer Pricing Regulations:

The Finance Act 2023 emphasizes transfer pricing regulations to prevent the manipulation of prices in cross-border transactions between related parties. It mandates that transactions between related parties must be conducted at arm’s length, ensuring that prices are aligned with market values.

The introduction of stringent transfer pricing regulations promotes tax transparency and helps prevent profit shifting to low-tax jurisdictions.

2. Controlled Foreign Company (CFC) Rules:

The Finance Act 2023 introduces Controlled Foreign Company (CFC) rules, targeting the taxation of passive income earned by foreign subsidiaries of Nigerian companies. Under these rules, passive income earned by CFCs may be subject to taxation in Nigeria.

The CFC rules aim to prevent tax base erosion and ensure that income earned by foreign subsidiaries is appropriately taxed in Nigeria.

3. Digital Services Tax (DST):

In response to the digital economy’s growing significance, the Finance Act 2023 introduces a Digital Services Tax (DST) on certain digital transactions. This tax applies to non-resident companies providing digital services to Nigerian customers, and it is levied at a specified percentage of the gross transaction value.

The DST seeks to capture revenue from digital transactions and ensure that digital service providers contribute to Nigeria’s tax revenue.

4. Withholding Tax on Cross-Border Transactions:

The Finance Act 2023 enhances withholding tax requirements for cross-border transactions. It may require businesses to withhold tax on certain payments made to non-resident individuals or companies, such as royalties, technical fees, and dividends.

The withholding tax provisions aim to ensure that non-resident taxpayers meet their tax obligations in Nigeria.

5. Avoidance of Double Taxation:

The Act addresses the issue of double taxation by providing tax credits or exemptions for taxes paid in foreign jurisdictions. This measure ensures that income subject to taxation in both Nigeria and another country is not taxed twice.

The avoidance of double taxation promotes international trade and investment, encouraging foreign investors to do business in Nigeria.


The Nigeria Finance Act 2023 introduces significant changes to the taxation of cross-border transactions, aligning the country’s tax laws with global best practices and fostering tax transparency. Through transfer pricing regulations, CFC rules, the Digital Services Tax, withholding tax enhancements, and measures to avoid double taxation, the Act seeks to create a more equitable and conducive environment for businesses engaged in international trade and investment.

As a reputable accounting firm in Nigeria, we advise businesses involved in cross-border transactions to stay informed about the implications of the Finance Act 2023 and seek professional guidance to ensure compliance with the updated tax regulations. By embracing these changes, businesses can navigate the complexities of cross-border taxation, promote tax compliance, and contribute to Nigeria’s economic growth and global competitiveness.

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