State Taxation of Digital Services: A Partnership with the State Inland Revenue Service.


The digital revolution has transformed the way business is conducted worldwide, and Nigeria is no exception. With the growth of the digital economy, new challenges and opportunities have arisen, especially in the realm of taxation. The State Inland Revenue Service (SIRS) in Nigeria recognizes the importance of adapting tax policies to the digital era while ensuring a fair and efficient tax system. In this article, we will explore the state taxation of digital services and the partnership between digital service providers and the SIRS to navigate this evolving landscape.

The Rise of Digital Services:

Digital services encompass a wide range of online activities, from e-commerce and digital advertising to software-as-a-service (SaaS) and streaming media. These services have become integral to our daily lives and are often provided by multinational tech giants and local startups alike.

Tax Challenges in the Digital Economy:

The borderless nature of digital services presents unique tax challenges:

  1. Tax Jurisdiction: Determining the appropriate taxing jurisdiction for digital transactions can be complex, as services are often delivered remotely.
  2. Profit Shifting: Some digital companies use complex structures to shift profits to low-tax jurisdictions, resulting in potential revenue loss for host countries.
  3. VAT/GST Collection: Collecting value-added tax (VAT) or goods and services tax (GST) on digital services can be challenging, particularly when providers are based abroad.
  4. Regulatory Compliance: Keeping up with rapidly changing digital services and business models requires agile and adaptable tax regulations.

The SIRS Approach to Digital Taxation:

The SIRS recognizes the need to adapt to the digital age and has implemented several measures:

  1. Digital VAT/GST: The SIRS has introduced mechanisms for collecting VAT/GST on digital services consumed within the state, ensuring that revenue is not lost to offshore providers.
  2. Tax Treaties: Nigeria has entered into tax treaties and agreements with other countries to address cross-border tax challenges and prevent double taxation.
  3. Transfer Pricing Guidelines: The SIRS has issued transfer pricing guidelines to prevent profit shifting by digital companies.
  4. Taxpayer Education: The SIRS provides guidance and education to digital service providers, helping them understand their tax obligations.

The Partnership Between Digital Service Providers and the SIRS:

Digital service providers can contribute to a fair and efficient tax system through collaboration with the SIRS:

  1. Transparency: Digital service providers can maintain transparent financial records and cooperate with tax authorities to ensure accurate taxation.
  2. Local Presence: Establishing a local presence can facilitate tax compliance and regulatory adherence.
  3. Tax Compliance Software: Utilizing tax compliance software can help digital companies automate tax calculations and submissions.
  4. Educational Initiatives: Engaging in educational initiatives with the SIRS can foster a culture of tax compliance within the digital industry.


State taxation of digital services is a necessary adaptation to the realities of the digital economy. The State Inland Revenue Service plays a pivotal role in shaping tax policies that are fair, efficient and adaptable to the evolving digital landscape. Digital service providers, whether global giants or local startups, can contribute to this endeavor by embracing transparency, local presence and tax compliance best practices. By working together, the SIRS and digital service providers can ensure that the digital economy thrives while fulfilling its tax obligations, contributing to Nigeria’s economic growth and development.

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.