AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
For an ordinary private Irish company paying a Nigerian contractor for services, Revenue's Professional Services Withholding Tax applies to fees paid by state and semi-state bodies, not private payers, so the usual position is that you pay the invoice in full. Nigerian withholding tax is a duty that PwC describes for Nigerian payers, and a Nigerian-resident contractor reports the fee in Nigeria. PwC's Nigerian treaty list (reviewed 29 May 2026) does not include Ireland, so there is no treaty rate to apply.
The short version
An Irish company that pays a designer in Ibadan or a software consultancy in Lagos usually asks two things: must we deduct Irish tax before paying, and does Nigeria expect us to deduct anything? For most private Irish businesses buying services, the answer to the first is no, and the second is a question about Nigerian payers, not Irish ones. The detail matters, because the exceptions catch people.
The Irish side: PSWT is for public bodies
Ireland's main withholding regime for fees is Professional Services Withholding Tax (PSWT). Revenue's page for non-residents (published 17 September 2024) says PSWT is withheld when you provide "a professional service to a state or semi-state body", and the provider then claims a credit on Form 11 or Form CT1. Non-residents give the tax reference number from their country of residence, and can claim using Form IC11.
If your company is a government department, local authority, health body or another public body, check whether you are an accountable person and whether the service is a professional service. If you are a private company, Revenue's page does not describe any PSWT duty for you.
Other Irish withholding rules exist for particular kinds of payment, such as certain interest and royalties. If what you are paying is a licence fee for software, music or a patent rather than a fee for work done, ask your tax adviser whether a different rule applies before you pay.
The Nigerian side: withholding is a payer's duty in Nigeria
PwC's Nigeria withholding tax summary (reviewed 29 May 2026) lists rates that Nigerian payers deduct. For consultancy, technical, management and professional fees:
| Recipient | Rate shown by PwC | Note |
|---|---|---|
| Nigerian-resident company or individual | 5% | Vendors without a Tax ID can face twice the rate, up to 20% |
| Non-resident company | 10% | Final tax for technical, consultancy, professional or management services |
Those rates describe what a Nigerian business deducts when it pays a supplier. Your situation is the reverse: a foreign payer with no Nigerian presence paying a Nigerian resident. Whether an Irish company with no Nigerian entity is a withholding agent under the Nigeria Tax Administration Act is not something the pages we opened answer. In practice the contractor, not you, carries the Nigerian tax: PwC says Nigerian residents are taxed on worldwide income, so the contractor declares your fee in a Nigerian return.
If your company does have a Nigerian subsidiary or branch that pays the contractor, Nigerian withholding rules then apply to that entity. See our cross-link on withholding tax on invoices in Nigeria.
No Ireland–Nigeria treaty
PwC's list of Nigeria's double tax treaties names 15 countries: Belgium, Canada, China, the Czech Republic, France, the Netherlands, Pakistan, the Philippines, Romania, Singapore, Slovakia, South Africa, Spain, Sweden and the United Kingdom. Ireland is not on it. So there is no treaty rate to quote and no treaty form for the contractor to sign. If anyone asks you for a "treaty certificate" for Ireland–Nigeria, ask which treaty they mean.
What you should still do
- Check status. Make sure the person is a genuine contractor and not an employee in substance. If they are an employee, Nigerian PAYE applies instead; see contractor or employee.
- Collect an invoice. It should show the contractor's name, address, Nigerian Tax ID if they have one, the service, period and amount.
- Deal with VAT. A Nigerian supplier's service to your Irish business is usually taxed where you are established, and you self-account. See reverse charge VAT on Nigerian services.
- Keep the evidence for your deduction. Section 81 of the Taxes Consolidation Act 1997 allows a deduction only for money wholly and exclusively laid out for the trade. Keep the contract, invoices, deliverables and payment records.
- Watch the presence question. A contractor who signs deals on your behalf in Nigeria can create a taxable presence; see permanent establishment risk.
If the contractor trades through a Nigerian company
Some Nigerian contractors invoice through their own limited company registered with the CAC. The Irish position does not change: you are still a private payer buying a service. On the Nigerian side, the fee becomes the company's income and is reported in its company tax return rather than a personal one. Ask for the company's name, registration number and Tax ID on the invoice so your records match the entity you pay, and pay only into an account in that company's name.
Worked example
Example. A Cork software firm pays a Lagos developer a monthly fee of €3,000 under a consultancy agreement. The firm is a private company, so PSWT does not arise. It pays €3,000 in full, records the invoice, self-accounts for VAT on the received service, and claims the €3,000 as a business expense. The developer declares €3,000 a month (converted to naira) as income in Nigeria. Nobody deducts tax at source.
Where Pryme fits
A Pryme Business Account lets you pay a Nigerian contractor in euro or naira, and bulk payouts handle several at once. Each payment carries its own record, and the app shows the rate and the fee before you approve.
Questions people ask
Do I need to deduct Irish withholding tax when paying a Nigerian freelancer?
Not as a private company paying for services, on Revenue's PSWT page, which covers fees paid by state and semi-state bodies. Royalty and interest payments follow other rules.
Is there a double tax treaty between Ireland and Nigeria?
PwC's list of Nigeria's treaties (reviewed 29 May 2026) does not include Ireland.
What is the Nigerian withholding tax rate on consultancy fees?
PwC lists 5% for Nigerian residents and 10% for non-resident companies, deducted by Nigerian payers.
Who pays tax on the fee in Nigeria?
A Nigerian-resident contractor is taxed on worldwide income and declares the fee in their own Nigerian return.
Sources
- Revenue: PSWT for non-residents (published 17 Sep 2024) · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, corporate withholding taxes (reviewed 29 May 2026) · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, foreign tax relief and tax treaties (reviewed 29 May 2026) · accessed Oct 2026
- Taxes Consolidation Act 1997, s.81 (Irish Statute Book) · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, taxes on personal income (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.