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ARTICLE · 28 JUNE 2022

Reciprocity In Tax Administration: Are There Limits?

It is not uncommon for countries to reach bilateral or multilateral agreements to protect their citizens from multiple taxation on the same income, ease international relations and encourage global mobility.

NigeriaTax

It is not uncommon for countries to reach bilateral or multilateral agreements to protect their citizens from multiple taxation on the same income, ease international relations and encourage global mobility. One of such agreements is the double tax treaty (DTT) which basically protects companies / individuals against double taxation of the same income and allows taxpayers that have suffered tax on an income in one country to claim foreign tax credit to offset tax liabilities in another country based on the relevant agreement.

Recently, the Federal Inland Revenue Service (FIRS) issued a Circular ("the Circular") titled "Information Circular on the Claim of Tax Treaties Benefits and Commonwealth Tax Relief in Nigeria". The Circular was issued further to the FIRS' public notice communicating the Honourable Minister of Finance, Budget and National Planning ("the Minister")'s approval of the discontinuation of the unilateral application of a uniform Withholding Tax (WHT)

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