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The short answer
Under Nigeria's Withholding Tax Regulations 2024, a Nigerian company paying management, technical, consultancy or professional fees to a non-resident company deducts withholding tax at 10%, and for a non-resident with no Nigerian tax presence that deduction is the final tax. The UAE is not on the FIRS list of 16 tax treaties in force (Circular 2022/15), so there is no reduced treaty rate to claim; the domestic 10% applies.
Many Nigerian founders now run a group from Dubai or Abu Dhabi: a UAE holding or operating company at the top, a CAC-registered company in Lagos doing the work on the ground. Sooner or later the parent wants to charge the Nigerian company for head-office services, and the first question from the Lagos accountant is how much to withhold. This page sets out what the published rules say, where the treaty question stands, and the two Nigerian filings that decide whether the money can actually leave.
The rate: 10% for a non-resident recipient
The Deduction at Source (Withholding) Regulations 2024 took effect on 1 July 2024. PwC Nigeria's summary of the regulations and Mondaq's overview both give the same split for commission, management, technical, consultancy and professional fees: 5% where the recipient is resident in Nigeria, 10% where it is non-resident. A UAE parent with no office, staff or other taxable presence in Nigeria is a non-resident recipient.
- Final tax: for a non-resident without a Nigerian tax presence, the 10% deduction is described as the final Nigerian tax on that fee. The parent does not file a Nigerian return for it.
- No TIN: the regulations set twice the normal rate where the recipient has no Tax ID. PwC notes that in practice this mostly hits non-residents, so check whether your parent should register.
- Who deducts: the paying Nigerian company deducts, remits to the tax authority and issues the receipt itself; under the 2024 rules the paying company, not the tax office, issues the receipt.
- When: PwC's summary gives remittance by the 21st of the month after the deduction.
PwC's Nigeria withholding tax page, reviewed on 29 May 2026, still describes withholding on non-resident companies' technical, professional, management and consultancy fees as final. Whether the Nigeria Tax Act 2025 has changed the 2024 rates was not confirmed on any page we opened in October 2026, so ask your tax adviser to check the current schedule before the first payment. The Nigeria Revenue Service (NRS) has replaced FIRS as the collecting authority.
The treaty question: no reduced rate for the UAE today
Treaty rates only matter if a treaty is in force. FIRS Information Circular 2022/15, dated 11 May 2022, lists 16 treaties in force: Italy (air and shipping only), the UK, Belgium, Pakistan, the Czech Republic, Slovakia, France, the Netherlands, Romania, Canada, South Africa, China, the Philippines, Sweden, Spain and Singapore. The UAE is not on that list. PwC's May 2026 treaty table does not show a UAE rate either.
Two practical consequences follow. First, the parent cannot ask the Lagos company to apply a lower rate by showing a UAE tax residency certificate. Second, if a treaty does come into force later, the circular sets the process: the non-resident sends a certificate of residence endorsed by its home tax authority, a letter to the Executive Chairman, and a beneficial-owner and no-permanent-establishment declaration; the treaty rate then works only as a cap where the domestic rate is higher. We track the current position in our note on the Nigeria-UAE treaty status.
Worked example
Example only. The Lagos subsidiary is invoiced ₦10,000,000 for a quarter's management services by its Dubai parent, which has a Nigerian Tax ID.
| Line | Amount |
|---|---|
| Invoice from UAE parent | ₦10,000,000 |
| WHT deducted at 10% | ₦1,000,000 |
| Paid to the parent | ₦9,000,000 |
| WHT if parent has no Tax ID (twice the rate, 20%) | ₦2,000,000 |
| Paid to the parent in that case | ₦8,000,000 |
The ₦1,000,000 is remitted by the Lagos company and receipted to the parent. Under the UAE's own corporate tax rules, how the parent treats that Nigerian tax is a separate question for its UAE adviser.
Before any money leaves: NOTAP and transfer pricing
NOTAP registration
A management services agreement between a Nigerian company and a foreign party is a technology transfer agreement for NOTAP's purposes. NOTAP's published requirements give a guide range for management services fees of 1% to 5% of profit before tax, and list the documents: two copies of the agreement, NOTAP forms, MEMART, the foreign company's profile, TIN and tax clearance, three years' audited accounts, and evidence of capital importation where it applies. Banks seek NOTAP confirmation before remitting these fees.
KPMG's note on the Court of Appeal decision in Stanbic IBTC v FRCN and NOTAP (2019) explains the consequence of skipping this step: an unregistered agreement is not void, but no licensed bank may make the payment to a person outside Nigeria without the NOTAP certificate. In practice the fee stays in Nigeria.
Transfer pricing
A fee from a subsidiary to its parent is a controlled transaction. KPMG's summary of the 2018 Transfer Pricing Regulations exempts connected persons whose controlled transactions are under ₦300 million from contemporaneous documentation, though documentation may still be requested. Grant Thornton's January 2025 note says the TP declaration and disclosure are filed with the company income tax return. The fee also has to be priced as an independent party would price it; a fee that looks like a profit extraction invites challenge.
What to check first
- Does the parent have a Nigerian Tax ID? If not, register it or expect double the rate.
- Is the services agreement written, dated and registered with NOTAP?
- Is the fee priced on a defensible basis, with TP documentation if you are over the threshold?
- Who issues the WHT receipt each month, and by when is the tax remitted?
- Has your adviser confirmed the 2024 rates still stand under the Nigeria Tax Act 2025?
If the Nigerian company's own payroll and filings are handled from abroad, see running a CAC company while living in the UAE, and the Nigeria-side detail in Nigerian withholding tax for non-resident companies.
Where Pryme fits
A Pryme Business Account for the Nigerian company holds naira, dollars, pounds and euros in one place, so the fee can be paid out in the currency the parent invoices once the bank paperwork is in order. The Finance agent can prepare the monthly WHT schedule and receipts for a person to approve, and multicurrency accounts keep each currency separate. Conversions through Swap show the rate and the fee before you approve.
Questions people ask
What WHT rate applies to management fees paid to a Dubai company?
Under the 2024 Withholding Tax Regulations, 10% for a non-resident company, and it is the final Nigerian tax where the recipient has no Nigerian tax presence. Without a Nigerian Tax ID the rate doubles.
Can my UAE company use a tax residency certificate to pay less WHT in Nigeria?
Not at present. The UAE is not on the FIRS list of 16 treaties in force, so there is no treaty rate to claim.
Do I need NOTAP approval to pay a management fee abroad?
In practice yes. Banks ask for NOTAP's certificate before remitting, and without it a licensed bank may not make the payment outside Nigeria.
Is there VAT as well as WHT on fees from a UAE parent?
VAT on imported services is a separate question from WHT. Ask your Nigerian tax adviser how it applies to your contract before invoicing.
Sources
- PwC Nigeria: Highlights of the Deduction at Source (Withholding) Regulations 2024 · accessed Oct 2026
- Mondaq: An overview of the Nigerian Withholding Tax Regulations of 2024 · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, corporate withholding taxes, reviewed 29 May 2026 · accessed Oct 2026
- FIRS Information Circular 2022/15 on claiming tax treaty benefits (hosted by KPMG Nigeria), 11 May 2022 · accessed Oct 2026
- NOTAP: Updated requirements for the registration of technology transfer agreements · accessed Oct 2026
- KPMG Nigeria: The Court of Appeal judgment on the effect of agreements not registered with NOTAP (Aug 2019) · 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.