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)