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The short answer
There are two routes. In Spain, Article 24 of the Spain–Nigeria agreement allows a deduction for income tax paid in Nigeria, capped at the Spanish tax on that income, for income Nigeria may tax under the agreement. In Nigeria, a treaty claim under FIRS Circular 2022/15 can stop the deduction at source. Because Article 14 gives Spain alone the right to tax most freelance fees, the Nigeria route is often the one that fits.
You invoiced a Nigerian company, it kept back 10% as withholding tax (WHT), and you have a receipt. Can you get that money back, or at least avoid paying tax twice? The answer depends on reading two documents together: Nigeria's withholding rules and the Spain–Nigeria double taxation agreement. This guide explains both. It is information, not tax advice; a gestor or asesor fiscal should review your case.
Step one: get the receipt right
Under Nigeria's 2024 Withholding Tax Regulations, the payer issues the receipt, not the tax authority. Mondaq's overview says it should show your name, address and Tax ID, the nature of the payment, the gross amount, the amount deducted and the month. PwC's summary adds that you get credit for the deduction even if the customer did not pay it over, and a customer that issues receipts without remitting is itself liable. Ask for one receipt per payment and check the figures against your invoice.
Why the treaty has no "services rate"
People often look for a treaty rate for freelance fees. There is not one. The Spain–Nigeria agreement (signed 23 June 2009, published in Spain's BOE on 13 April 2015) caps Nigerian tax on dividends, interest and royalties, and PwC's Nigeria table lists Spain at 7.5% for those. For professional services the agreement works differently: Article 14 says a Spain resident's income from professional or other independent activities "shall be taxable only in that State" unless the person has a fixed base regularly available in Nigeria. For business profits, Article 7 gives the same result unless there is a permanent establishment. And there is no article on fees for technical services.
So for a freelancer working from Spain with no base in Nigeria, the treaty does not reduce the Nigerian rate; it removes Nigeria's right to tax the fee.
Route A: relief in Nigeria
FIRS Information Circular 2022/15, the latest published guidance we found (issued before the NRS replaced FIRS), describes how a non-resident claims a treaty benefit:
- A certificate of tax residence endorsed by your home tax authority (the Agencia Tributaria).
- A letter to the Executive Chairman, attention Director of Tax Policy and Advisory.
- Declarations that you are the beneficial owner and have no permanent establishment in Nigeria.
- Evidence for the income type (the circular details dividends and interest only).
On approval, a copy goes to your client as withholding agent. The circular is about applying the treaty position when paying; it is silent on refunds of tax already withheld. If tax has already been deducted, ask the NRS in writing how a refund is claimed, quoting Article 14. Doing the claim before the next payment is usually easier than chasing a refund.
If Nigeria and you disagree
Article 26 of the agreement provides a mutual agreement procedure: you may present your case to the tax authority of your state of residence within three years of the first notification of the action that results in tax not in line with the agreement.
Route B: a credit in Spain
Article 24 says that where a resident of one state has income which, "in accordance with the provisions of this Agreement, may be taxed in the other Contracting State", the home state allows a deduction equal to the income tax paid there, but not more than the home-state tax on that income. Two consequences:
- Where Nigeria may tax the income under the treaty (for example dividends, interest or royalties at the capped rates, or fees connected with a fixed base in Nigeria), Spain allows the credit, up to the Spanish tax on that income.
- Where only Spain may tax (most freelance fees under Article 14), the wording suggests Spain need not credit tax Nigeria should not have charged. Ask your gestor how the AEAT treats it in your annual return before you count on the credit.
Worked example of the cap
| Example figures | Amount |
|---|---|
| Royalty income from Nigeria, gross | €10,000 |
| Nigerian tax withheld at a 7.5% treaty rate | €750 |
| Spanish tax attributable to that income (example) | €2,500 |
| Credit allowed: the lower of the two | €750 |
| Spanish tax still due on that income | €1,750 |
Check: €2,500 less €750 is €1,750. If the Spanish tax on that income had been €600, the credit would stop at €600.
What to keep
- Each invoice, the WHT receipt and the bank credit, filed together.
- Your AEAT residence certificate and the treaty claim, with the date sent.
- Any NRS correspondence, so you can show the three-year clock if you need Article 26.
How the deduction is calculated in the first place is in will my Nigerian client deduct withholding tax? The Nigerian side of credit notes is explained on our Nigerian site at getting your WHT credit notes back.
Where Pryme fits
With Pryme invoicing, the gross fee, WHT and net amount sit on one invoice, and the Compliance agent in a Business Account can track which clients have sent receipts. Verifiable statements from VerifyDoc.ai give your gestor a record that can be checked.
Questions people ask
Can I get Nigerian WHT refunded?
Published Nigerian guidance (FIRS Circular 2022/15) covers applying the treaty when paying, not refunds. Ask the NRS in writing how a refund is claimed, citing Article 14.
What is the Spain–Nigeria treaty rate for freelance fees?
There is none. Article 14 makes professional income of a Spain resident taxable only in Spain unless there is a fixed base in Nigeria.
Can I deduct Nigerian WHT from my Spanish tax?
Article 24 allows a deduction for tax Nigeria may charge under the agreement, capped at the Spanish tax on that income. Whether it applies to fees Nigeria should not have taxed is a question for your gestor.
Is there a deadline for disputes?
Under Article 26 a case must be presented within three years of the first notification of the action causing the problem.
Sources
- Spain–Nigeria double taxation agreement, English text (Ministerio de Hacienda) · accessed Oct 2026
- Convenio entre el Reino de España y la República Federal de Nigeria (BOE, 13 Apr 2015), 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
- 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
- PwC Worldwide Tax Summaries: Nigeria, corporate withholding taxes (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.