AI agents for business finance: what they can and can't do
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The short answer
A Nigerian payer will normally want three things before it applies the UK–Nigeria treaty: a current HMRC certificate of residence naming the treaty article, your tax identifiers (UK UTR, and a Nigerian Tax ID if you have or need one), and an invoice that describes the service clearly enough to place it under that article. Even with all three, the payer may still deduct at the domestic rate, so agree the treatment in writing before the work starts.
The UK–Nigeria Double Taxation Convention dates from 1987 and has no separate article for technical or management fees. That is why the paperwork matters: the same piece of work could be read as business profits (Article 7), independent personal services (Article 14), royalties (Article 12) or an entertainer's income (Article 17), and each gives a different answer on how much Nigeria may tax.
What the treaty allows
| Income | Treaty article | What it says |
|---|---|---|
| Freelance professional work | Art 14 | Taxable only in the UK unless you have a fixed base regularly available in Nigeria |
| Business profits | Art 7 | Taxable only in the UK unless you have a permanent establishment in Nigeria |
| Royalties | Art 12 | Nigeria may tax, capped at 12.5% of the gross |
| Performances in Nigeria | Art 17 | Nigeria may tax where the performance takes place |
Nigeria's 2025 tax reforms kept existing treaties in force: KPMG's analysis notes that section 121 of the Nigeria Tax Act preserves them. The same analysis says WHT on services from abroad is a final tax for non-resident companies, so a deduction that should not have happened is not something the payer will refund through a later return.
The evidence pack
- Certificate of residence. Apply to HMRC online; it names the UK–Nigeria convention, the income type and the article. See our step-by-step.
- Tax identifiers. Your 10-digit UTR. The Nigeria Tax Administration Act 2025 expects non-residents supplying taxable services into Nigeria to register for a Tax ID; whether your payer insists on one is worth asking (more on the TIN question).
- A contract that places the work. Say where the work is done (the UK), that you have no office or fixed base in Nigeria, and what the payment is for.
- An invoice that matches the contract. Describe the service in the same words. "Consultancy delivered remotely from London" reads differently from "fee".
- A written note of the agreed treatment. One email from the payer's finance team saying which rate they will apply, or that they will not deduct.
When tax is deducted anyway
Many payers deduct at the domestic rate regardless, because their systems or their auditors require it. Under the 2024 Regulations that is 10% for non-resident consultancy, professional, management and technical fees, and 5% for other services, as summarised by PwC. The payer must give you a receipt showing the gross amount, the amount deducted and the month.
Here the treaty works against you in an unexpected way. Article 22 gives UK credit for Nigerian tax payable "in accordance with this Agreement". If Article 14 says Nigeria should not tax your consultancy at all, HMRC's HS263 helpsheet explains that tax deducted above what the treaty allows is not creditable in the UK and may only be recoverable from the foreign authority. You could pay tax twice on the same income unless you reclaim from Nigeria.
Worked example
Example only. You invoice £4,000 for remote advisory work. The payer deducts 10%, £400, and pays £3,600. Your UK tax on that £4,000 of profit, at a 20% marginal rate, is £800. If the work is treated as Article 14 income with no Nigerian fixed base, the treaty allows Nigeria nothing, so HMRC may allow no credit and you owe the full £800 in the UK, on top of the £400 already taken. If instead the payer had agreed not to deduct, you would have received £4,000 and paid £800 in the UK. The £400 is the price of missing paperwork.
For royalties the picture is kinder. Nigerian WHT on royalties to an individual is 5% under the 2024 Regulations, inside the 12.5% treaty cap, so it is generally creditable against UK tax on the same income, up to the UK tax due.
What to check first
- Which article the payer thinks applies, and why.
- Whether the payer needs the certificate for the tax year of payment.
- Whether a Nigerian Tax ID is required for their system.
- Whether their adviser wants a Nigerian-format residence form, which HMRC can certify.
- That the WHT receipt names you exactly as on your certificate.
Where Pryme fits
Getting paid the agreed net amount, in the agreed currency, is the last step. A Pryme Business Account gives you naira and sterling details in one place, and invoicing keeps the article wording and your identifiers on every invoice. The Finance agent, built by Pryme Intelligence, can prepare a reconciliation of gross, WHT and net for each client for you to approve (Finance agent). For the Nigerian rules in more depth, see Nigerian WHT for non-residents.
Questions people ask
Can a Nigerian company pay me without deducting WHT if I am UK resident?
The treaty can support that for Article 14 or Article 7 income, but the payer decides in practice. Ask for written agreement before invoicing.
What is the treaty rate on royalties from Nigeria?
Article 12 caps Nigerian tax on royalties at 12.5% of the gross.
Can I claim UK credit for all Nigerian WHT deducted?
Only for tax Nigeria was entitled to under the treaty, up to the UK tax on that income, per HS263.
Did the 2025 Nigerian tax reforms cancel the UK treaty?
No. KPMG's analysis says section 121 of the Nigeria Tax Act preserves existing treaties.
Sources
- UK–Nigeria Double Taxation Convention 1987 (GOV.UK PDF) · accessed Oct 2026
- GOV.UK: How to apply for a certificate of residence to claim tax relief abroad (last updated 26 Jun 2024) · accessed Oct 2026
- HMRC: Relief for foreign tax paid 2026 (HS263, updated 6 Apr 2026) · accessed Oct 2026
- PwC Nigeria: highlights of the Deduction of Tax at Source (Withholding) Regulations 2024 · accessed Oct 2026
- Mondaq (KPMG): the Nigeria Tax Act and non-resident companies (13 Aug 2025) · accessed Oct 2026
- Nigeria Tax Administration Act 2025 (gazette 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.