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
To do a locum in Nigeria you need a current Nigerian practising licence (MDCN for doctors, NMCN for nurses); your HPCSA or SANC registration only covers South Africa, so keep it paid while you are away. The fee is Nigerian-source income: an independent locum is taxable in Nigeria under the treaty only with a fixed base or over 183 days, but a hospital may still deduct 10% withholding, and SARS taxes the fee with a credit for Nigerian tax properly due.
A Nigerian doctor or nurse who lives in South Africa and goes home for a few weeks of locum cover is dealing with three separate systems at once: the Nigerian regulator that licenses you to treat patients in Nigeria, the South African regulator that keeps your registration for work in South Africa, and two tax authorities that may both have a claim on the locum fee. Most of the confusion comes from treating these as one question. They are not, and the order in which you deal with them matters.
The licence that lets you work in Nigeria
Treating patients in Nigeria depends on your Nigerian registration and a current annual practising licence, not on your South African registration. For doctors that is the Medical and Dental Council of Nigeria (MDCN). Its December 2025 briefing note says licences are issued in the fourth quarter of the year and run for twelve months from 1 January of the following year, that you can renew at any point in the year through the MDCN portal, and that from 2026 late payment attracts surcharges under its Registration Guidelines. The note gives no fee amounts and says nothing specific about practitioners based abroad, so check the portal for the current fee before you book flights.
Nurses and midwives renew with the Nursing and Midwifery Council of Nigeria (NMCN). Its renewal page, last seen with a 2022 footer, describes a three-year licence renewed online at licence.nmcn.gov.ng and paid through Remita, with a recent photo, registration certificates and a continuing professional development attendance certificate uploaded. Fees on that page are marked as subject to review, so treat any figure you have seen as a starting point and confirm on the portal.
- Lapsed licence: if you have not renewed since you moved, expect surcharges and possibly continuing education to catch up on before a hospital will roster you.
- Hospital credentialing: the hospital will normally want to see your current licence, not just your registration certificate. Ask the medical director what they need in writing.
- Specialist status: if you are being booked as a consultant, make sure your additional qualifications are registered with the MDCN; its 2025 note mentions waivers on surcharges for late registration of additional qualifications.
Your South African registration while you are away
Your Health Professions Council of South Africa (HPCSA) registration, or South African Nursing Council registration for nurses, governs your work in South Africa, not in Nigeria. The practical risk is letting it lapse while you are focused on the trip. We could not confirm from an official HPCSA page in October 2026 what it requires of practitioners who work outside South Africa for short periods, so before you go ask the council directly whether anything changes for your category, and keep paying the annual fee so you do not face a restoration process when you return.
How the locum fee is taxed in Nigeria
Work you physically do in a Nigerian hospital produces Nigerian-source income. A September 2026 Mondaq summary of the Nigeria Tax Act notes that a non-resident's income accruing in or derived from Nigeria is chargeable, and that non-residents with income other than passive income should register with the Nigeria Revenue Service (NRS) Non-Resident Persons Tax Office and obtain a Tax ID. Whether you actually owe Nigerian tax then depends on how the locum is structured.
| How you are engaged | Treaty article that applies | Where it can be taxed |
|---|---|---|
| Independent locum, invoicing the hospital | Article 14 (independent personal services) | Nigeria only if you have a fixed base regularly available there, or are present more than 183 days in a 12-month period |
| Employee of the Nigerian hospital, even short term | Article 15 (dependent personal services) | Nigeria, because the employer is resident there |
| Through your own SA company billing the hospital | Articles 5 and 7 (business profits) | Nigeria only if the company has a permanent establishment there |
Separately, the 2024 Nigerian withholding tax regulations set 10% for professional and consultancy fees paid to non-residents, described as a final tax unless you have a Nigerian tax presence; a hospital paying you as an independent contractor may deduct it. If you believe the treaty means Nigeria should not tax the fee, ask the hospital before the first payment what evidence of South African residence it needs to apply that, and get the deduction receipt either way: you need it for any credit in South Africa.
How South Africa treats it
The South Africa-Nigeria treaty (in force since 5 July 2008) has South Africa deduct Nigerian tax paid on income that Nigeria may tax from the South African tax on the same income, capped at the share of South African tax that income bears. SARS's provisional tax page says anyone who receives income other than a salary is a provisional taxpayer, so a locum fee on top of your South African salary normally puts you into the IRP6 cycle: first payment by 31 August, second by the last business day of February for a March-to-February year.
Worked example (illustrative figures only)
Suppose a hospital agrees a fee of ₦4,000,000 for four weeks and deducts 10% withholding tax. You receive ₦3,600,000 and a receipt for ₦400,000. In South Africa you declare the full ₦4,000,000, converted to rand under SARS's currency rules, and claim a credit for the ₦400,000 only if Nigeria was entitled to tax it under the treaty; if it was not, the route is a refund from Nigeria, not a credit from SARS.
What to check first
- Renew your MDCN or NMCN licence online and keep the receipt.
- Confirm with your South African council and employer that your registration and leave are in order.
- Agree in writing whether you are an employee or an independent locum, and the gross fee.
- Ask the hospital whether it will deduct withholding tax and request the receipt.
- Keep the contract, rota, payslip or invoice and payment proof for SARS.
Where Pryme fits
A Pryme Business Account can be opened from South Africa and receive the naira fee into local Nigerian account details, so it does not have to be converted on arrival; Swap shows the rate and the fee before you approve any conversion. You can issue the hospital an invoice through Pryme invoicing and keep a verifiable statement for SARS. Outside Nigeria, Pryme's activities are carried out through regulated partners.
Questions people ask
Can I work as a locum in Nigeria with only my HPCSA registration?
No. HPCSA registration covers practice in South Africa. In Nigeria you need your MDCN registration and a current annual practising licence, renewed on the MDCN portal.
Do I pay Nigerian tax on a two-week locum?
It depends on how you are engaged. As an independent locum, the treaty lets Nigeria tax you only if you have a fixed base there or stay over 183 days in a 12-month period. As an employee of a Nigerian hospital, Nigeria can tax the pay. A hospital may still deduct withholding tax.
Do I declare the locum fee to SARS?
Yes, if you are South African tax resident. Declare the gross fee converted to rand and claim a credit for Nigerian tax that Nigeria was entitled to under the treaty.
Will the MDCN charge me extra for a late renewal?
MDCN's December 2025 note says late payments attract surcharges from 2026 under its Registration Guidelines. It does not publish the amounts in that note, so check the portal.
Sources
- MDCN: Recent news (annual practising licence briefing, December 2025) · accessed Oct 2026
- NMCN: Renewal of licence · accessed Oct 2026
- SARS: South Africa-Nigeria double taxation agreement (Government Gazette 31241, 22 July 2008) · accessed Oct 2026
- Mondaq (Nolands): Taxation of non-resident individuals in Nigeria, 30 September 2026 · accessed Oct 2026
- Mondaq: An overview of the Nigerian Withholding Tax Regulations of 2024 · accessed Oct 2026
- SARS: Provisional Tax (updated 21 August 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.