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The short answer
A Nigerian subsidiary pays dividends to its US parent after deducting 10% withholding tax, with no US-Nigeria treaty to reduce the rate. Repatriation in dollars runs through an authorised dealer bank and depends on the original investment having been documented with a Certificate of Capital Importation, plus evidence that the tax has been paid.
Profits made in Lagos are only useful to a US parent once they are declared, taxed and converted. Nigerian law guarantees the right to repatriate after tax, but the paperwork at the start of the investment decides how smoothly that works years later. This guide covers the tax, the documents and the foreign exchange step, as at October 2026. It is information, not tax or legal advice.
Step one: the dividend and its tax
Dividends come out of profits after Nigerian company income tax. PwC's Nigeria summary (reviewed 29 May 2026) shows company income tax at 30% for companies above the small-company line (turnover over ₦100,000,000 or fixed assets over ₦250,000,000), plus a 4% development levy on assessable profits for companies that are not small.
When the dividend is paid, PwC's withholding tax table shows 10% for non-resident companies. The IRS treaty list shows no US income tax treaty with Nigeria, so no treaty rate applies. The subsidiary deducts the tax, remits it, and gets a receipt; that receipt is part of the repatriation file.
Worked example
Example figures only, and assuming assessable profit equals accounting profit, which in real life it rarely does exactly.
| Line | Amount |
|---|---|
| Profit before tax | ₦200,000,000 |
| Company income tax at 30% | ₦60,000,000 |
| Development levy at 4% | ₦8,000,000 |
| Profit after tax | ₦132,000,000 |
| Dividend declared (all of it) | ₦132,000,000 |
| Withholding tax at 10% | ₦13,200,000 |
| Net dividend available to remit | ₦118,800,000 |
At an example rate of ₦1,500 per dollar, the net ₦118,800,000 is $79,200. The real dollar figure depends on the rate on the day the bank converts.
Step two: the CCI and the right to repatriate
NIPC's FAQ says Nigeria's investment laws guarantee foreign investors the right to freely repatriate profits, dividends and capital after payment of applicable taxes, and lists the CCI among required documents with evidence of share capital inflow. Mondaq (19 September 2024) explains that the CCI is issued by an authorised dealer, usually the commercial bank that received the capital, on behalf of the CBN, and that it enables repatriation of dividends and profits net of tax in any convertible currency. Templars notes that without a CCI an investor cannot access the official FX market for repatriation.
If the original share capital went in without a CCI, for example because the founder paid it locally in naira, speak to the bank and a Nigerian lawyer before declaring the dividend. Fixing it later is harder than doing it at the start.
Step three: the documents the bank will ask for
Repatriation goes through the authorised dealer bank. Expect a request for:
- The CCI (or CCIs) for the capital invested.
- The board resolution declaring the dividend, and the audited accounts it is paid from.
- Evidence of tax paid: the withholding tax receipt, and tax clearance, which Mondaq lists for dividend and interest remittances.
- The parent's receiving account details, matching the name on the CCI.
- Any bank-specific form or letter of instruction.
Why remittances stall
- The name on the receiving US account does not match the investor named on the CCI.
- The CCI describes the inflow as a loan when the money is now being returned as a dividend, or the other way round.
- The withholding tax receipt or tax clearance is missing or in the wrong period.
- Part of the share capital was paid locally in naira and never covered by a CCI.
- Audited accounts for the year the dividend comes from are not yet signed.
Each of these is cheaper to prevent than to fix, which is why the repatriation file should be built from the day capital first arrives.
Step four: FX timing
The dividend is in naira until the bank converts it. Pavestones' summary of the CBN Foreign Exchange Manual effective 1 June 2026 describes eCCI registration within 24 to 48 hours of inflow; it does not give a timeline for outward dividend remittance. Templars (c. 2020) said repatriation was typically within 24 hours of request or at the next auction window, but that predates current rules, so ask the bank how long it takes today and at what rate. Plan for the rate on the conversion day being different from the rate when the dividend was declared.
On the US side
When the dollars arrive, the parent records the dividend and its US adviser deals with how it is taxed and whether the Nigerian withholding tax is creditable. If the parent holds the naira for a while before converting, any rate movement is a Section 988 item; see FX gains and losses on naira balances. A separate guide covers the US tax and FX side of a Nigerian subsidiary's dividend.
Where Pryme fits
A Pryme Business Account holds NGN and USD in one place for the subsidiary's day-to-day money, and Swap shows the rate and fee before you approve. For a formal dividend repatriation against a CCI, work with the authorised dealer bank named on the CCI. Verifiable statements through VerifyDoc.ai help when auditors or the bank ask for proof of balances.
Questions people ask
What is the withholding tax on dividends from Nigeria to a US company?
PwC's table shows 10% for non-resident companies. There is no US-Nigeria income tax treaty to reduce it.
Can I repatriate dividends from Nigeria without a CCI?
Templars says without a CCI an investor cannot access the official FX market for repatriation. Speak to the bank and a lawyer before declaring the dividend.
How long does dividend repatriation from Nigeria take?
No current official timeline was found. Ask the authorised dealer bank for its current timeline and rate.
Does Nigeria guarantee profit repatriation?
NIPC says investment laws guarantee the right to freely repatriate profits, dividends and capital after payment of applicable taxes.
Sources
- PwC Worldwide Tax Summaries: Nigeria, withholding taxes (reviewed 29 May 2026) · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, taxes on corporate income (reviewed 29 May 2026) · accessed Oct 2026
- NIPC: Frequently asked questions · accessed Oct 2026
- Mondaq (Adeola Oyinlade & Co): How to repatriate capital and profits in Nigeria as a foreign investor (19 Sep 2024) · accessed Oct 2026
- Templars: Repatriation of funds and capital importation in Nigeria, FAQs (c. 2020) · accessed Oct 2026
- Mondaq (Pavestones Legal): The CBN Foreign Exchange Manual 2026 (24 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.