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
Under the Nigeria Tax Act 2025, in force from 1 January 2026, a Nigerian company pays company income tax at 30% if its turnover exceeds ₦100 million or its fixed assets exceed ₦250 million, and at 0% if it is a small company below both. Companies other than small and non-resident ones also pay a 4% development levy on assessable profits. The self-assessment return is due within six months of year end, according to PwC's May 2026 summary.
The rates by company size
The 2025 tax laws replaced the old three-tier system. PwC's Worldwide Tax Summaries, reviewed in May 2026, set out the current position.
| Company | Test | CIT rate | Development levy |
|---|---|---|---|
| Small company | Turnover of ₦100m or less and fixed assets not above ₦250m | 0% | Exempt |
| Large company | Turnover above ₦100m or fixed assets above ₦250m | 30% | 4% of assessable profits |
| Very large company or group | Turnover of ₦50bn or more, or part of a multinational group with turnover of €750m or more | 30%, with top-up to a 15% minimum effective rate | 4% of assessable profits |
The development levy replaces several older charges, which PwC lists as tertiary education tax at 3%, the NITDA levy at 1%, the NASENI levy at 0.25% and the Police Trust Fund levy at 0.005%. PwC's June 2025 guide to the reforms also notes that small companies are exempt from capital gains tax as well as CIT and the levy, and that the capital gains tax rate for other companies rose from 10% to 30%.
PwC's summary describes no general turnover-based minimum tax for ordinary companies under the new law.
Is a US-owned subsidiary a small company for tax?
The tax test in PwC's summary turns on turnover and fixed assets. That is a different test from the CAMA small-company definition used for audit exemption, which also looks at who the members are. A US-owned subsidiary can therefore be small for tax and still need an audit; see the annual audit guide. PwC's page uses "and" in one place and "or" in another when describing the thresholds, so if your subsidiary is close to either figure, confirm the reading with your adviser before relying on the 0% rate.
A worked example
Figures are examples only.
- Turnover
- ₦300,000,000, so the company is large
- Assessable profit
- ₦40,000,000
- CIT at 30%
- ₦12,000,000
- Development levy at 4%
- ₦1,600,000
- Total
- ₦13,600,000, before any withholding tax credits the company holds
Had the same company kept turnover at ₦90,000,000 with fixed assets below ₦250,000,000, both lines would be nil, although it would still file a return.
Filing, paying and penalties
- Return. Self-assessment within six months after the financial year end, or within 18 months of incorporation if earlier. The NRS may extend by up to two months.
- Payment. Due with the return; instalments are possible on written application by the filing date.
- Late filing. ₦100,000 for the first month and ₦50,000 for each later month.
- Late payment. 10% of the tax plus interest at the monetary policy rate plus a spread.
- Look-back. Additional assessments can generally be raised within six years, longer for fraud or wilful default.
All of these come from PwC's corporate tax administration summary reviewed in May 2026. The tax year for companies follows the calendar year in the new framework; a subsidiary with a different accounting year should check how the transition applies.
The Rev360 portal
According to a Templars client alert of 13 May 2026, the Nigeria Revenue Service launched Rev360 on 30 April 2026 to replace TaxPro Max, with registration, filing, payment, refunds and tax clearance in one place. Rollout is phased, starting with medium and emerging taxpayers. Existing profiles and balances were to migrate automatically; Templars advises checking that withholding tax credits, losses and capital allowances came across correctly.
What to have ready before the return
- Audited or at least final accounts for the year, since the tax computation starts from them.
- A capital allowances schedule for fixed assets bought and sold.
- The list of withholding tax credit notes received from customers, to set against the liability.
- Intercompany agreements and invoices with the US parent.
- Evidence for any claim to be a small company: turnover and the fixed asset register at year end.
Dealings with the US parent
Payments between the subsidiary and the parent draw attention. PwC's group taxation summary says Nigeria's transfer pricing rules follow the OECD approach, apply to cross-border and domestic connected-party dealings, and let the tax authority adjust prices that are not at arm's length. From 1 January 2026, interest on connected-party loans is deductible only up to 30% of EBITDA, with excess carried forward for up to five years. There is no group relief, so the subsidiary's losses cannot be set against the parent's profits in Nigeria. See transfer pricing and intercompany loans.
On the US side, the parent may have to report the subsidiary's income under the controlled foreign corporation rules; see is a Nigerian company a CFC.
Where Pryme fits
The Compliance agent on a Pryme Business Account can keep the filing calendar and prepare the schedules for a person to approve. See Compliance agent.
Questions people ask
What is the company income tax rate in Nigeria in 2026?
30% for companies with turnover above ₦100 million or fixed assets above ₦250 million, and 0% for small companies below both, under the Nigeria Tax Act 2025 as summarised by PwC in May 2026.
What is the development levy in Nigeria?
A 4% levy on assessable profits of companies other than small and non-resident companies. It replaced tertiary education tax and several other levies.
When is the CIT return due for a Nigerian subsidiary?
Within six months after the financial year end, or within 18 months of incorporation if earlier. The NRS can extend by up to two months.
Can a US-owned Nigerian company be a small company for tax?
Yes, if it meets the turnover and fixed-asset tests. That is separate from the CAMA small-company test for audit, which a US-owned company usually fails.
Sources
- PwC Worldwide Tax Summaries: Nigeria, taxes on corporate income (reviewed 29 May 2026) · accessed Oct 2026
- PwC Nigeria: The Nigeria Tax Reform Acts, top 20 changes to know (Jun 2025) · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, corporate tax administration (reviewed 29 May 2026) · accessed Oct 2026
- Templars: From TaxPro Max to Rev360, client alert (13 May 2026) · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, group 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.