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The short answer
Under art. 165 of the TUIR, an Italian tax resident can deduct from Italian IRPEF the tax paid in Nigeria on income produced there, as long as the Nigerian tax is final ("a titolo definitivo") and the credit does not exceed the Italian tax on the same income. Because the Italy-Nigeria tax agreement covers only air and shipping, the credit works under Italian law alone, and you need Nigerian documents showing the income and the tax actually paid.
What the credit does
Italy taxes residents on income from everywhere. If you live in Milan and earn rent, interest, dividends or fees in Nigeria, Nigeria may tax that income first because it arises there, and Italy taxes it again because you live in Italy. Art. 165 of the Testo Unico delle Imposte sui Redditi (TUIR) removes most of the overlap: the tax already paid in Nigeria becomes a credit against the IRPEF due in Italy.
The credit only works in one direction. It reduces Italian tax; it never produces an Italian refund of Nigerian tax. If Nigerian tax is higher than the Italian tax on the same income, the excess is simply lost.
No general treaty: why that matters
Readers often assume Italy and Nigeria have a full double tax treaty. The FIRS information circular of May 2022 lists Italy among Nigeria's treaties but marks it "air and shipping only". The NiDCOM diaspora guide of January 2026 lists Italy among treaty partners without that qualification, so the two sources should be read together: for salaries, rent, interest or dividends there is no treaty article cutting Nigerian withholding rates or deciding which country may tax first.
- Nigerian withholding applies at its domestic rate, with no treaty reduction to claim.
- The Italian credit rests on art. 165 TUIR alone, which applies to income produced abroad regardless of a treaty.
- Nigeria, for its part, gives a unilateral credit to its own residents for foreign tax even without a treaty, according to the NiDCOM guide, which helps if you are resident in Nigeria rather than Italy.
More on the treaty itself is in the Italy-Nigeria tax agreement.
The four conditions
- Income produced abroad
- The income must arise in Nigeria under Italian rules on source, for example rent on a Nigerian building or interest from a Nigerian bank.
- Included in Italian income
- The income must be part of your Italian taxable total. Art. 165, comma 8 denies the credit if the return is omitted or the foreign income is left out of the return you filed.
- Final foreign tax
- Only tax paid definitively counts. Payments on account, provisional amounts and anything you could get back are excluded.
- Within the ceiling
- The credit is capped at Italian gross tax multiplied by foreign income divided by total income, and cannot exceed the net tax for the year.
EC News (June 2023) notes that the Corte di Cassazione, in ordinance 9725/2021, and several lower courts have allowed the credit after an assessment even where no return had been filed, but always on proof of the foreign tax paid. That is a dispute route, not a filing plan.
Is Nigerian withholding "definitive"?
This is the point to settle with an adviser before you claim. Much Nigerian tax on a non-resident's income is collected by withholding: 10% on rent deducted by the tenant or agent, according to the NiDCOM guide, and withholding on dividends, which Mondaq (September 2026) describes as the final tax for non-residents with only passive income. Where a withholding is final and cannot be refunded, it fits the "a titolo definitivo" test. Where Nigerian law treats it as an advance against a later assessment, only the amount finally due after that assessment counts. None of the official or professional sources we checked in October 2026 settles whether rent withholding is final for a non-resident individual under the Nigeria Tax Act 2025, so keep the evidence of both the deduction and any Nigerian return.
Papers that prove Nigerian tax paid
- Withholding tax credit notes or receipts issued by the tenant, bank or company that deducted the tax, showing your name and Tax ID.
- Your Nigerian return, if you filed one, and the assessment or acknowledgement from the Nigeria Revenue Service (NRS).
- Bank statements showing the gross amount and the net receipt.
- Where an Italian office asks for formal proof, a Nigerian tax clearance certificate; Mondaq (March 2025) notes these are applied for online with your tax identification number and are valid for one year.
- A sworn Italian translation if the Agenzia delle Entrate asks for one.
Getting the Nigerian side in order starts with a Tax ID: see getting a Nigerian tax ID from Italy and Nigerian certificates for Italian use.
What to check first
- Are you Italian tax resident for the year? If not, art. 165 is not your route.
- Which Nigerian income did you have, and was tax withheld or assessed on it?
- Is that Nigerian tax final, or could it be refunded or adjusted?
- Do you hold documents in your own name that show the tax paid?
- Will your return include the income? Leaving it out loses the credit.
Where Pryme fits
Keeping Nigerian income in one Pryme account makes the trail easier to follow, and a verifiable statement generated through VerifyDoc.ai lets your commercialista confirm the figures are unaltered. Pryme does not prepare tax returns; this is information, not advice.
Questions people ask
Does Italy give credit for tax I paid in Nigeria?
Yes. Art. 165 TUIR lets an Italian resident deduct Nigerian tax paid definitively on Nigerian income, up to the Italian tax on that income.
Is there a double tax treaty between Italy and Nigeria?
Only for air and shipping, according to the FIRS circular of May 2022. For other income the Italian credit applies under domestic law.
What proof of Nigerian tax do I need for the Agenzia delle Entrate?
Documents showing the income and the tax definitively paid: withholding credit notes or receipts, your Nigerian return and assessment if any, and bank statements. Keep them in case the office asks.
What happens if I forget to declare the Nigerian income?
Under art. 165, comma 8, the credit is denied if the foreign income is not in the return. Some courts have allowed it later on proof of payment, but that is not something to rely on.
Sources
- EC News: Il credito per le imposte pagate all'estero nella dichiarazione (e in sua mancanza) (22 Jun 2023) · accessed Oct 2026
- FIRS Information Circular 2022/15 on claiming tax treaty benefits (11 May 2022, hosted by KPMG) · accessed Oct 2026
- NiDCOM: NGEX Diaspora Guide to Nigeria's tax reforms (Jan 2026) · accessed Oct 2026
- Mondaq: Taxation of non-resident individuals in Nigeria (30 Sep 2026) · accessed Oct 2026
- Mondaq: How to obtain a tax clearance certificate in Nigeria (7 Mar 2025) · 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.