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The short answer
It depends on your status. SARS says estate duty is levied on the property of residents and on the South African property of non-residents, so a Nigerian who is resident in South Africa at death can have Nigerian land and accounts counted, while a non-resident's Nigerian assets are outside it. Duty is 20% on the dutiable estate up to R30 million (25% above) after a R3.5 million basic deduction.
The SARS rules in brief
SARS's "Other taxes" page (updated 26 February 2026, no change from the previous year) sets out estate duty:
- Who is caught
- Duty is "levied on property of residents and South African property of non-residents", less allowable deductions.
- Basic deduction
- R3.5 million.
- Rate
- 20% on the first R30 million of dutiable value; 25% above R30 million.
- Deductions named
- Liabilities, bequests to public benefit organisations and property passing to a surviving spouse.
Estate duty is separate from income tax. Your status for estate duty is decided under estate duty law, so do not assume your income tax status settles it; ask SARS or an estate practitioner if you have recently arrived or are about to leave.
Applying it to a Nigerian in South Africa
| Your status at death | SA property | Nigerian land, house, shares, accounts |
|---|---|---|
| Resident | Included | Included in the estate SARS values |
| Non-resident | Included | Outside SA estate duty |
A Nigerian who has lived in Johannesburg for years with family, home and work there is the case most likely to be treated as resident, which brings a house in Enugu or shares on the NGX into the calculation.
Worked example (illustrative)
Example only. Femi is resident in SA and leaves a Pretoria house worth R2,800,000, an investment account of R900,000, a Lagos plot valued at R1,800,000 and a naira account worth R500,000: R6,000,000 in total. He owes R500,000 on a bond.
| Step | Amount |
|---|---|
| Gross estate | R6,000,000 |
| Less liabilities | R500,000 |
| Net estate | R5,500,000 |
| Less basic deduction | R3,500,000 |
| Dutiable amount | R2,000,000 |
| Estate duty at 20% | R400,000 |
If everything passed to his surviving spouse, the spouse deduction could remove most or all of the duty. If Femi were non-resident, only the Pretoria house and SA investments would count: R3,700,000 less the R500,000 bond is R3,200,000, below the R3.5 million deduction, so no duty.
Treaties and the Nigerian side
The South Africa–Nigeria double taxation agreement is the treaty PwC lists for relief from double income tax; we found nothing in the sources we read showing it covers estate duty, so do not rely on it to remove Nigerian assets from an SA estate. Explaining the treaty's scope is in the double tax agreement explained.
In Nigeria, the Nigeria Tax Act 2025 does not treat inheritance as a chargeable disposal for capital gains, and heirs take assets at their market value at death, according to Bloomberg Tax (2 February 2026). Nigerian probate is a separate process with its own costs: your heirs will usually need letters of administration or a grant of probate in Nigeria to deal with Nigerian assets (see letters of administration for a bank claim in Nigeria).
What to check first
- Work out whether you would be treated as resident for estate duty today.
- List Nigerian assets with a recent value, and the documents your heirs would need (C of O, deed of assignment, CSCS statement).
- Check whether your will covers Nigerian assets or whether you need a separate Nigerian will: does an SA will cover property in Nigeria.
- Ask how the spouse deduction applies to your marital regime.
Practical points for an estate in two countries
An estate with assets in both countries is usually handled twice: once by the executor in South Africa, who winds up the estate under South African law and deals with SARS, and once in Nigeria, where the family needs authority from a Nigerian probate registry before banks, registrars or land offices will deal with them. The two processes run on their own timetables and neither recognises the other automatically.
- Valuations: SARS needs a rand value for Nigerian assets at the date of death if you are resident. Get a dated valuation from a Nigerian valuer and keep the naira figure and the conversion.
- Liquidity: estate duty is payable in South Africa in rand. If most of the value sits in Nigerian land, the SA estate may need cash from elsewhere to pay the duty.
- Documents: the original title documents for Nigerian land are often in Nigeria. Tell your executor and a trusted relative where they are.
- Insurance and retirement benefits follow their own rules; check how each is treated before counting it.
Where Pryme fits
Executors struggle most with assets nobody can find. Keeping Nigerian money in one Pryme account in naira alongside USD, GBP and EUR, with verifiable statements available through our partner VerifyDoc.ai, makes it easier to show what existed and its value (multicurrency account, statements). This page is information, not legal or tax advice.
Questions people ask
Does South Africa charge estate duty on foreign assets?
For residents, yes: SARS says duty is levied on the property of residents. For non-residents, only South African property is included.
What is the estate duty rate in South Africa?
20% on the first R30 million of dutiable value and 25% above, after a R3.5 million basic deduction, per SARS's February 2026 page.
Does the SA–Nigeria tax treaty cover estate duty?
We found nothing in the sources we read showing it does. It is listed as a treaty for relief from double income tax.
Is there inheritance tax in Nigeria?
Under the Nigeria Tax Act 2025, inheritance is not a chargeable disposal for capital gains, per Bloomberg Tax. Nigerian probate still has its own process and costs.
Sources
- SARS: Other taxes, including donations tax and estate duty (updated 26 February 2026) · accessed Oct 2026
- Bloomberg Tax: New Nigeria tax law redefines capital gains tax for individuals (2 February 2026) · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, individual foreign tax relief and tax treaties (reviewed 29 May 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.