AI agents for business finance: what they can and can't do
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The short answer
You can keep a UK limited company after moving to Nigeria; it remains a UK company with UK filing duties and, under HMRC's incorporation rule, stays UK tax resident. The risk is on the Nigerian side: the Nigeria Tax Act 2025 can treat a company whose central or effective place of management or control is in Nigeria as a Nigerian company, which could expose its profits to Nigerian tax as well.
What stays the same
Your company does not change nationality when you board a plane. It is still registered at Companies House, still files annual accounts and a confirmation statement, still pays UK Corporation Tax on its profits, and still needs a registered office in the UK. A registered office has to meet Companies House's appropriate address rule, so your old flat or a forwarding service you no longer control may not do; see the appropriate address rule.
HMRC's International Manual (INTM120060, updated 20 October 2026) says the central management and control test for company residence now matters only for companies not incorporated in the UK and for UK-incorporated companies that fall within an exception to the incorporation rule. In plain terms, a normal UK-incorporated company remains UK resident for UK tax wherever its directors live.
What changes: Nigeria may also claim the company
Nigeria looks at the question differently. KPMG Nigeria, writing on Mondaq on 23 January 2026, says section 201 of the Nigeria Tax Act defines a Nigerian company as one formed or registered in Nigeria, or whose central place of management or control is in Nigeria, or whose effective place of management or control is in Nigeria. The Act does not define "management or control". KPMG says a company treated as Nigerian may be subject to Companies Income Tax at 30% on its worldwide income, plus a 4% development levy.
If you are the only director and you take every decision from Lagos, the company's management is arguably in Nigeria. That does not stop it being UK resident; it can make it resident in both. The UK-Nigeria double taxation agreement does not have an automatic tie-breaker for companies: Article 4(3) says the two tax authorities settle the question by mutual agreement. That is slow and uncertain, so most owners try to avoid the problem in the first place. The full analysis is in UK company managed from Nigeria: tax residence risk.
Your own tax as director
Separate from the company, your personal tax changes. GOV.UK says non-residents only pay UK tax on UK income, while UK residents normally pay on all their income. Once you are Nigerian resident, Nigeria taxes residents on worldwide income, according to PwC's Nigeria summary. Salary and dividends from the UK company are treated differently under the treaty; see tax on salary and dividends for a UK director living in Nigeria.
Practical checklist
| Item | What to sort before or soon after the move |
|---|---|
| Registered office | A UK address that meets the appropriate address rule and forwards post promptly |
| Director identity verification | Check you have met Companies House identity rules; see ID verification for Nigerian directors |
| Bank account | Tell your UK bank about your new address; some restrict accounts for non-resident directors |
| Board decisions | Decide where and by whom key decisions are taken, and minute them |
| Accountant | One who can act for you remotely and file on time |
| Nigerian tax | Register for a Nigerian tax ID as an individual and take local advice on the company |
Ways owners reduce the dual residence risk
- Appoint a UK-resident director who takes part in real decisions, not just signs.
- Hold board meetings in the UK, physically or by video with the decision-makers in the UK, and record them.
- Keep the company's commercial base in the UK: customers, contracts and staff.
- If the business is really moving to Nigeria, consider setting up a Nigerian company instead and winding down the UK one.
These are factors tax authorities look at, not a safe harbour. HMRC's manual says control can sit with a shareholder rather than the board, as it did in Bullock v Unit Construction, so a UK director who only rubber-stamps your decisions may not help.
Permanent establishment: a separate question
Even if the company is not Nigerian resident, running UK business from a Lagos office can create a permanent establishment in Nigeria. Article 5 of the treaty counts a place of management, a branch or an office as a permanent establishment. Our guide on whether a UK company can create a taxable presence in Nigeria covers that test.
Where Pryme fits
A Pryme Business Account can be opened from any country and holds pounds, naira, dollars and euros with local details, so a UK company with costs in Lagos can pay them without moving everything into naira first. Conversion happens only when you choose, with the rate and fee shown first. See business multicurrency accounts.
Questions people ask
Can I keep my UK company if I move back to Nigeria?
Yes. It remains a UK company with UK filings and UK Corporation Tax. The question is whether Nigeria also treats it as Nigerian because it is managed from there.
Does my UK company become Nigerian if I run it from Lagos?
It can be treated as a Nigerian company for tax. Section 201 of the Nigeria Tax Act includes companies whose central or effective place of management or control is in Nigeria, according to KPMG Nigeria.
Can my UK registered office be my Nigerian address?
No. A UK company's registered office must be in the UK and meet Companies House's appropriate address rule.
Which country taxes the company if both claim it?
Under Article 4(3) of the UK-Nigeria treaty, the two tax authorities settle it by mutual agreement.
Sources
- HMRC International Manual INTM120060: company residence, central management and control (updated 20 Oct 2026) · accessed Oct 2026
- Mondaq (KPMG Nigeria): Place of effective management and control under the Nigeria Tax Act (23 Jan 2026) · accessed Oct 2026
- GOV.UK: 1987 UK-Nigeria double taxation agreement, in force · accessed Oct 2026
- GOV.UK: Tax on foreign income, residence (updated 1 Oct 2026) · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, individual taxation (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.