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The short answer
Under the Nigeria Tax Act 2025, in force since 1 January 2026, you are Nigerian tax resident if any one of several tests applies: domicile, a permanent home available for your use, habitual abode, 183 days or more in any 12-month period, or substantial economic or immediate family ties. You stop being resident only when none of them applies, so a flight to London alone does not end it. Once non-resident, Nigeria taxes you only on Nigerian-source income such as rent.
Many people assume that leaving Nigeria ends Nigerian tax the day the plane lands at Heathrow. Under the law in force since 1 January 2026, it is not that simple. This guide sets out the Nigerian tests, how they meet the UK rules, and what to put in place in your first year away. It is information, not tax advice.
The Nigerian tests since 1 January 2026
PwC's summary of the Nigeria Tax Act 2025 (last reviewed 29 May 2026) lists the conditions that make an individual resident. Meeting any one is enough:
- you are domiciled in Nigeria;
- you have a permanent place available for your domestic use in Nigeria;
- Nigeria is your habitual abode;
- you are in Nigeria for 183 days or more in any 12-month period, counting temporary absences;
- you have substantial economic ties or immediate family ties in Nigeria;
- you serve as a Nigerian diplomat or official abroad.
PwC adds that you are non-resident only where all of these are absent. A resident is taxed on income wherever it arises; a non-resident only on Nigerian-source income. The diaspora guide NiDCOM published in January 2026 describes residence mainly through the 183-day count. The fuller list above is what the summary of the Act sets out, so do not rely on the day count alone.
Why the move itself is not the end point
The day count is the easy part. The other tests depend on facts, not dates, and several of them often survive a move:
| What you left behind | Which test it touches | What to think about |
|---|---|---|
| House or flat in Nigeria kept empty for visits | Permanent home available for your use | A home you can walk back into points towards residence |
| House let to tenants on a long lease | Permanent home; economic ties | Not available to you while let, but rent is still Nigerian income |
| Spouse and children still in Lagos or Abuja | Immediate family ties | This can keep you resident even after a full year away |
| Active business or directorship in Nigeria | Economic ties | What counts as 'substantial' is not defined in the summaries we read |
| Frequent long visits home | 183 days in any 12 months | The window is any 12 months, not only January to December |
The Act's phrase 'substantial economic ties' is broad, and the sources we read do not give a threshold. If your position depends on it, take advice from a Nigerian chartered tax adviser before you file.
Worked example: a move in March 2026
Example. Tunde leaves Lagos for a job in Manchester on 1 March 2026. He lets his Lekki flat on a two-year lease. His wife and two children follow on 15 July 2026. He spends ten days in Lagos in December.
- Days: about 59 days in Nigeria from January to February, plus 10 in December, so about 69 days in 2026. Under 183 days in any 12-month window that starts after his move.
- Home: the flat is let, so it is not available to him while the lease runs.
- Family: immediate family were in Nigeria until mid-July. That tie existed for part of the year.
- Economic ties: the rent is Nigerian income, but whether one let flat is a 'substantial' tie is not settled in the sources we read.
On these facts Tunde is probably non-resident from the second half of 2026, but the family tie earlier in the year and the rental flat make it a case to check, not assume. If both countries treat him as resident, the UK–Nigeria tax treaty's tie-breaker decides, which our guide to the two-country tie-breaker walks through.
How the UK side fits
The UK uses its own statutory residence test. GOV.UK says you are automatically UK resident if you spend 183 days or more in the UK in the tax year, and that residents normally pay UK tax on all their income, whether from the UK or abroad. Our guide to the statutory residence test for Nigerians covers the detail.
The two systems do not talk to each other, so you can be resident in both. Article 4 of the 1987 UK–Nigeria treaty then looks, in order, at where you have a permanent home, where your vital interests lie, where you habitually live and your nationality, with the two tax authorities agreeing between them as a last step. The treaty decides which country has first claim for treaty purposes; it does not stop Nigeria applying its own tests in the first place.
What to put in place in your first year
- Keep proof of your departure date: boarding pass, UK tenancy start, employment contract.
- Keep a simple log of every day in Nigeria from now on, so you can test any 12-month window.
- Decide what happens to your Nigerian home. Note in writing if it is let and to whom.
- Tell your Nigerian employer you have left, so PAYE stops at the right point.
- If you still earn rent or other Nigerian income, expect to file in Nigeria as a non-resident. Our guide on filing a Nigerian return from abroad explains when.
- If you later return home, the tests run in reverse: see when Nigerian tax starts again.
The Nigeria Revenue Service (formerly FIRS) and the state revenue services share the work: PwC notes that state services tax resident individuals while the NRS deals with non-residents. The Mypryme guide to the NRS explains how it is organised.
Where Pryme fits
A Pryme Personal account can be opened from the UK and holds naira, pounds, dollars and euros side by side, so rent from a let flat can arrive in naira and be kept apart from your UK salary. Separate balances make it easier to show a tax office what is Nigerian-source income. See multicurrency accounts.
Questions people ask
Do I stop being a Nigerian tax resident after 183 days in the UK?
Not by itself. Under the Nigeria Tax Act 2025, as PwC summarises it, 183 days in Nigeria is only one of several tests. A home kept available for you, family in Nigeria or substantial economic ties can keep you resident.
Does keeping my house in Nigeria make me tax resident?
It can, if it is a permanent place available for your use. A house let to tenants is not available to you while it is let, but the rent is still Nigerian income that Nigeria can tax.
Is my UK salary taxed in Nigeria after I move?
Only if you are still Nigerian resident. Non-residents are taxed only on Nigerian-source income, and NiDCOM's guide says income for services performed outside Nigeria is not taxable in Nigeria unless you are resident.
What if Nigeria and the UK both say I am resident?
The UK–Nigeria treaty's Article 4 tie-breaker looks at your permanent home, then vital interests, habitual abode and nationality, and finally agreement between the two tax authorities.
Sources
- PwC Worldwide Tax Summaries: Nigeria, individual residence (last reviewed 29 May 2026) · accessed Oct 2026
- NiDCOM / NGEX: Diaspora guide to Nigeria's tax reforms 2026 (Jan 2026) · accessed Oct 2026
- GOV.UK: Tax on foreign income, residence (updated 1 Oct 2026) · accessed Oct 2026
- UK–Nigeria Double Taxation Convention 1987 (GOV.UK PDF) · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, individual tax administration (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.