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ARTICLE · 24 MARCH 2026

Who Is A “Non-Resident Individual” Now? – Almost No One

On 26 June 2025, four new tax acts were signed into law, with two taking effect from 1 January 2026. One of the silent but most consequential changes buried in those pages is a clear but broadened legal definition of who a non-resident individual is, for tax purposes in Nigeria.

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On 26 June 2025, four new tax acts were signed into law, with two taking effect from 1 January 2026.  One of the silent but most consequential changes buried in those pages is a clear but broadened legal definition of who a non-resident individual is, for tax purposes in Nigeria.  The way the definition treats ties to Nigeria that are not simply measured in days spent in Nigeria will change how many ordinary people think about work, family, travel, and money.

The New Criterion: Defining the Non-Resident Individual

The Personal Income Tax Act (PITA) previously relied primarily on a 183-day physical presence rule to determine an individual's non-residency, and this was easily circumvented by individuals residing in diaspora. The 2025 Nigeria Tax Act closes this loophole by defining the concept of a non-resident individual.   For a person to qualify as a non‑resident individual, the quality of connection to Nigeria, not merely the number of days spent in the country,  is now put into

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