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
Usually yes, if your client is a Nigerian company: under the 2024 Withholding Tax Regulations a company paying a non-resident for professional, consultancy, technical or management services deducts 10% and treats it as final tax, according to PwC (reviewed May 2026). Individuals paying you are not required to deduct. The Spain–Nigeria tax treaty says professional income of a Spain resident is taxable only in Spain unless you have a fixed base in Nigeria, so you can ask for treaty relief, but it has to be claimed.
You live in Spain, you invoice a company in Lagos or Abuja, and the payment arrives short. In most cases the missing slice is Nigerian withholding tax (WHT): an amount the client keeps back from your fee and pays to the Nigerian tax authority on your behalf. Whether it should be deducted, at what rate, and whether the Spain–Nigeria treaty stops it are three separate questions. This guide takes them in order. It is information, not tax advice.
Who deducts, and who does not
Nigeria's Withholding Tax Regulations 2024 took effect on 1 July 2024. PwC's summary of the regulations says everyone except individuals is required to deduct. In practice that means:
- A Nigerian company, partnership or government body paying your invoice is expected to deduct WHT before paying you.
- An individual in Nigeria paying you personally (a private tutoring client, say) is not a deduction agent under the regulations as PwC summarises them.
- Small companies: the regulations exempt small companies (turnover under ₦25 million) from deducting where the supplier has a Tax ID and the transaction is ₦2 million or less in the month, according to Mondaq's overview. Most foreign freelancers will not hold a Nigerian Tax ID, so do not count on this.
The rate a Nigerian company will apply
PwC's Nigeria withholding tax table (reviewed 29 May 2026) lists professional, consultancy, technical and management fees paid to non-residents at 10%, against 5% for residents. Mondaq's overview of the 2024 regulations gives the same split and says the deduction from a non-resident is a final tax unless the recipient has a taxable presence in Nigeria. The same overview says a supplier without a Tax ID suffers twice the rate; PwC notes this tends to affect non-residents in practice. Ask your client which rate they intend to use before the first invoice.
Worked example
| Example invoice | Amount |
|---|---|
| Fee for design work, invoiced to a Lagos company | $2,000 |
| WHT at 10% (non-resident professional fee) | $200 |
| Paid to you | $1,800 |
| If the client applies twice the rate (no Tax ID) | $400 withheld, $1,600 paid |
The figures are an example. Whatever is withheld, the client should give you a receipt for it, which you will need later.
What the Spain–Nigeria treaty says about freelance fees
Spain and Nigeria signed a double taxation agreement in Abuja on 23 June 2009; Spain published it in the Boletín Oficial del Estado on 13 April 2015. Three articles matter to a freelancer:
- Article 14 (independent personal services): income a Spain resident earns from professional or other independent activities "shall be taxable only in that State unless he has a fixed base regularly available to him in the other Contracting State". Professional services include scientific, literary, artistic, educational and teaching work and the activities of engineers, lawyers, architects, accountants and similar.
- Article 7 (business profits): profits of an enterprise are taxed only where it is resident unless it trades through a permanent establishment in the other state.
- Article 5(3)(c): furnishing technical, management or consultancy services through employees or other personnel creates a permanent establishment only where the activity continues for more than six months in any twelve-month period.
There is no separate article on fees for technical services. So for a freelancer working from Spain with no office or regular base in Nigeria, the treaty points to Spain alone having the right to tax the fee. It does not, however, stop a Nigerian payer deducting by default: the payer needs to be shown the treaty applies.
How treaty relief is claimed in Nigeria
The last published guidance we found is FIRS Information Circular 2022/15 (11 May 2022), issued before the Nigeria Revenue Service (NRS) replaced FIRS. It lists Spain among Nigeria's 16 treaties in force and says a non-resident claiming a treaty benefit submits:
- A certificate of residence endorsed by the tax authority of the home country (for you, the Agencia Tributaria).
- A letter to the Executive Chairman, attention Director of Tax Policy and Advisory.
- Declarations that you are the beneficial owner of the income and have no permanent establishment in Nigeria.
- Supporting evidence for the type of income (the circular details dividends and interest; it does not list documents for service fees).
Once approved, a copy goes to the withholding agent, your client, which can then pay without the deduction or at the treaty position. The circular is silent on refunds and on service fees specifically, so ask the NRS what it needs for your case. If tax has already been taken, see our guide to reclaiming Nigerian withholding tax from Spain, and the wider picture in the Spain–Nigeria double tax treaty.
What to agree with your client first
- Whether they will deduct, at what rate, and whether they will accept a treaty claim.
- That your invoice is quoted gross, with WHT shown as a deduction, so the shortfall is not mistaken for a late or partial payment.
- That they will send the WHT receipt each time: Mondaq notes the deductor issues a receipt showing your name, address, Tax ID, the nature of the payment, gross amount, amount deducted and month.
- Who bears any bank charges, kept separate from the tax.
The Nigeria-side rules on credit notes are explained on our Nigerian site: withholding tax on invoices and getting your credit notes back.
Where Pryme fits
A Pryme Business Account can receive a Nigerian client's payment in naira or in dollars, and invoicing lets you show the gross fee and the deduction clearly. Keep the WHT receipt alongside a verifiable receipt or statement generated with VerifyDoc.ai, so your gestor in Spain can match the net payment to the gross invoice.
Questions people ask
Does an individual client in Nigeria deduct withholding tax from me?
According to PwC's summary of the 2024 regulations, individuals are not required to deduct. Companies and other organisations are.
What rate of WHT applies to a freelancer in Spain?
PwC's Nigeria table (reviewed May 2026) lists 10% for professional, consultancy, technical and management fees paid to non-residents, with twice the rate possible where the supplier has no Tax ID. Confirm with your client.
Does the Spain–Nigeria treaty stop the deduction automatically?
No. Article 14 gives Spain the taxing right for professional income where you have no fixed base in Nigeria, but your client will normally deduct unless an approved treaty claim is in place.
What proof do I need for my Spanish tax return?
The WHT receipt from your client for each payment, the invoice, and evidence of the amount received.
Sources
- PwC Worldwide Tax Summaries: Nigeria, corporate withholding taxes (reviewed 29 May 2026) · accessed Oct 2026
- Mondaq: an overview of the Nigerian Withholding Tax Regulations of 2024 · accessed Oct 2026
- PwC Nigeria: highlights of the Deduction at Source (Withholding) Regulations 2024 · accessed Oct 2026
- Spain–Nigeria double taxation agreement, English text (Ministerio de Hacienda) · accessed Oct 2026
- FIRS Information Circular 2022/15: claim of tax treaty benefits in Nigeria (11 May 2022, KPMG-hosted copy) · 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.