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The short answer
If you are UK resident, the UK taxes your Nollywood income wherever it is earned. Nigeria's right to tax depends on the work: under the UK–Nigeria treaty, an actor's fees for performing on set in Nigeria may be taxed in Nigeria, while editing, writing or post-production done in the UK is generally taxable only in the UK unless you have a fixed base in Nigeria. Where both countries tax the same income, the UK gives credit for Nigerian tax.
UK-based Nigerians work across the Nollywood value chain: actors who fly to Lagos for a shoot, editors and colourists cutting films in London, screenwriters, composers and producers pitching to Nigerian streaming commissions. Each role is taxed differently because the treaty between the two countries treats performers, independent professionals and rights income under separate articles.
The UK starting point
GOV.UK says UK residents normally pay UK tax on foreign income, usually reported through Self Assessment, and that relief may be claimed where income is taxed in more than one country. So every naira or dollar fee from a Nigerian production goes on your UK return, converted to pounds. The question is only whether Nigeria can tax it too.
What the treaty says, role by role
| Role | Treaty article | Can Nigeria tax it? |
|---|---|---|
| Actor or presenter performing on set in Nigeria | Article 17 (artistes) | Yes, income from performances there may be taxed in Nigeria |
| Actor paid through a loan-out company | Article 17(2) | Yes, even when the fee is paid to a company |
| Editor, writer, composer working from the UK as a freelancer | Article 14 (independent services) | Generally no, unless you have a fixed base regularly available in Nigeria |
| Employee of a Nigerian production company working on set in Nigeria | Article 15 (employment) | Yes, for work done in Nigeria |
| Royalties or licence fees for your script, music or film rights | Article 12 (royalties) | Yes, but capped at 12.5% of the gross |
The treaty's definition of royalties expressly includes copyright in literary and artistic works, including films and tapes for broadcasting.
Nigerian withholding tax in practice
Even where the treaty gives the UK the sole right, Nigerian producers often deduct withholding tax at source. Under the 2024 regulations as summarised by PwC, professional and consultancy fees paid to non-residents attract 10%, and royalties paid to non-resident individuals attract 5%. If the treaty says Nigeria should not tax a fee, ask the producer about applying treaty relief at source; that usually needs evidence of UK residence. See reduced Nigerian WHT under the UK treaty and getting an HMRC certificate of residence.
Avoiding double tax
Where Nigeria is entitled to tax, the UK gives credit. HMRC helpsheet HS263 says the credit is the lower of the foreign tax (limited to the treaty amount) and the UK tax on the same income. Nigerian tax deducted above the treaty rate is not creditable in the UK and has to be reclaimed from Nigeria.
Worked examples
Examples only.
- Actor: Tobi, UK resident, earns £8,000 for a three-week shoot in Lagos. Nigeria may tax it under Article 17. If £800 is withheld, she reports £8,000 in the UK and claims credit of up to £800, limited to the UK tax on that £8,000.
- Editor: Kelechi, UK resident, edits a series in Manchester for a fee of £6,000. With no fixed base in Nigeria, Article 14 gives the UK the right. If the producer withholds £600 anyway, the UK may not give credit for tax Nigeria was not entitled to, and Kelechi would need to reclaim it from Nigeria. Better to agree treaty relief before payment.
- Writer: Ronke licenses a screenplay for £4,000. Nigeria may tax the royalty at up to 12.5% under Article 12; if 5% (£200) is deducted she can claim UK credit for it, up to the UK tax on the royalty.
Expenses and residence
Your UK return can include allowable costs of earning the income, such as flights and hotels for a shoot that is wholly for business; see claiming a Nigeria work trip as a business expense. Long shoots also raise a residence question. Weeks spent in Nigeria count towards UK day tests, and a long enough absence can change your UK residence position under the statutory residence test. If a production will keep you in Nigeria for months, look at the residence rules before you sign.
Contracts and records
- Get the contract to say whether fees are gross or net of Nigerian tax.
- Ask for the WHT receipt for every payment.
- Keep a log of days on set in Nigeria and days working in the UK.
- If a production pays your per diems or flights, keep those agreements; they affect your UK expenses.
- Check visa rules if Nigerian work permits are needed for the shoot.
For live shows rather than film, see performing in Lagos in December.
Where Pryme fits
Productions often pay in naira. A Pryme Business Account can receive naira to local details and hold it alongside pounds, converting with Swap when you choose, with the rate and the fee shown first. Statements give you a dated record of each fee for your return.
Questions people ask
Do I pay UK tax on Nollywood income?
Yes, if you are UK resident. GOV.UK says UK residents normally pay UK tax on foreign income, with relief where it is taxed twice.
Can Nigeria tax an actor who lives in the UK?
Yes, for performances in Nigeria. Article 17 of the UK–Nigeria treaty lets the country where the performance happens tax the income.
Can Nigeria tax my editing fee if I work from London?
Under Article 14, independent professional income is generally taxable only in your country of residence unless you have a fixed base in the other country.
What is the treaty rate on film royalties?
Article 12 caps Nigerian tax on royalties at 12.5% of the gross amount; the 2024 Nigerian regulations set 5% for royalties paid to non-resident individuals.
Sources
- UK–Nigeria Double Taxation Convention 1987 (GOV.UK PDF) · accessed Oct 2026
- GOV.UK: Tax on foreign income (updated 1 Oct 2026) · accessed Oct 2026
- PwC Nigeria: highlights of the Deduction of Tax at Source (Withholding) Regulations 2024 · accessed Oct 2026
- HMRC: Relief for foreign tax paid 2026 (HS263, updated 6 Apr 2026) · accessed Oct 2026
- HMRC: RDR3 Statutory Residence Test guidance (updated 11 Jun 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.