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The short answer
Canada and Nigeria have a double taxation agreement signed in Abuja on 4 August 1992 and in force since 16 November 1999. It covers Canada’s federal income taxes and, for Nigeria, personal income tax, companies income tax, petroleum profits tax and capital gains tax. Its key rules for individuals are the residence tie-breaker (Article 4), employment income (Article 15), dividend and interest rates of 12.5% or 15% (Articles 10 and 11) and the foreign tax credit (Article 23).
Status of the agreement
The full name is the Agreement between the Government of Canada and the Government of the Federal Republic of Nigeria for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains, with a protocol. It was signed in Abuja on 4 August 1992 and entered into force on 16 November 1999 (Canada Treaty Series 1999/48). The text is on Global Affairs Canada’s treaty database. Either government can end it by written notice on or before 30 June of a year; no notice has been reported in the sources we checked, and the agreement is listed as in force.
Who and what it covers
Article 1 applies the agreement to people who are residents of one or both countries. Citizenship alone does not bring you in. Article 2 lists the taxes:
| Country | Taxes covered (Article 2) |
|---|---|
| Canada | Income taxes imposed by the Government of Canada |
| Nigeria | Personal income tax, companies income tax, petroleum profits tax and capital gains tax |
| Both | Any identical or substantially similar taxes introduced after signature |
Two practical points follow. First, Canadian provincial income tax is not named; on a Canadian return, relief for Nigerian tax comes through the federal foreign tax credit, with provincial credits worked out on the provincial form. Second, Nigeria’s 2025 tax reforms changed laws and agencies (the Nigeria Revenue Service replaced FIRS), but the treaty’s "substantially similar taxes" clause is designed to carry it across such changes.
The articles most readers need
- Article 4, residence
- If both countries treat you as resident, the tie-breakers apply in order: permanent home, centre of vital interests, habitual abode, nationality, then agreement between the tax authorities. A dual-resident company is resident where incorporated.
- Article 6, immovable property
- Income from land and buildings may be taxed where the property is. The protocol adds that, for Canada, this includes gains on disposal such as recaptured capital cost allowance.
- Article 10, dividends
- Source-country tax limited to 12.5% where the receiving company holds at least 10% of the voting power, and 15% in other cases.
- Article 11, interest
- Source-country tax limited to 12.5%.
- Article 13, capital gains
- Each country may tax gains under its own law; read with the credit in Article 23.
- Article 15, employment
- Salary is taxed only where you are resident unless the work is done in the other country. A short-stay exemption applies if you are there 183 days or fewer in a 12-month period, the employer is not resident there, and the pay is not borne by a base there.
- Article 16, directors’ fees
- May be taxed in the country where the company is resident.
- Article 18, pensions
- Taxable where you live and may also be taxed where they arise, under that country’s law; there is no percentage cap in the article.
- Article 23, relief
- Canada deducts Nigerian tax on Nigerian-source income from Canadian tax; Nigeria credits Canadian tax on Canadian-source income, capped at the Nigerian tax on that income.
- Article 25, disputes
- You can ask your own tax authority to take up double taxation within two years of the first notice of the action causing it.
- Article 26, information
- The tax authorities exchange information needed to apply the agreement or their domestic tax laws, kept secret like domestic data.
Note that Nigeria’s own withholding rates can be lower than the treaty maximum. PwC’s summary of the 2024 withholding regulations gives 10% on dividends and interest; a treaty cap only limits the source country, it never raises its tax. See claiming a foreign tax credit for Nigerian withholding tax.
What it does not do
- It does not exempt you from filing in either country.
- It does not cover social security contributions; that is a separate question, covered in whether Canada has a social security agreement with Nigeria.
- It does not stop Canada taxing its residents on world income; it decides who taxes first and how the other gives credit.
- It does not deal with gift or inheritance taxes, which are outside Article 2.
Using it in practice
On the Canadian side, you mostly use the treaty through the return: report the full foreign income in Canadian dollars, then claim the federal foreign tax credit on Form T2209 for Nigerian tax properly paid. The CRA’s foreign tax credit folio says that tax withheld above the treaty rate is not "foreign tax paid" for the credit; you would have to reclaim the excess from Nigeria. If you might be resident in both countries, read the tie-breaker rule first, because everything else depends on which country is your treaty residence.
Where Pryme fits
Treaty claims rest on records. A Pryme account, opened from Canada, keeps naira and dollar income in the currency it arrived in, and you can generate verifiable statements and receipts with VerifyDoc.ai to support a credit claim. See the multicurrency account.
Questions people ask
Is there a double tax treaty between Canada and Nigeria?
Yes. It was signed on 4 August 1992 and has been in force since 16 November 1999.
What is the treaty withholding rate on Nigerian dividends paid to Canadians?
Article 10 limits Nigerian tax to 12.5% for companies holding at least 10% of the votes and 15% otherwise. Nigeria’s domestic rate of 10% under the 2024 regulations is lower.
Does the treaty cover provincial tax?
Article 2 names only federal Canadian income taxes. Canada gives treaty relief through the federal foreign tax credit; provinces apply their own credits.
Can both countries tax my Nigerian rental income?
Yes. Nigeria may tax it where the property is, and Canada taxes its residents on world income but gives a credit for the Nigerian tax paid.
Sources
- Global Affairs Canada Treaty Law database: Agreement between Canada and Nigeria for the avoidance of double taxation (signed Abuja, 4 Aug 1992) · accessed Oct 2026
- Publications.gc.ca: Canada–Nigeria double taxation agreement with protocol (in force 16 Nov 1999, Canada Treaty Series 1999/48) · accessed Oct 2026
- PwC Nigeria: Highlights of the Deduction of Tax at Source (Withholding) Regulations 2024 · accessed Oct 2026
- CRA Income Tax Folio S5-F2-C1, Foreign Tax Credit (modified 31 Mar 2026) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.