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The short answer
The South Africa-Nigeria double tax agreement, in force since 5 July 2008, caps withholding at 7.5% or 10% on dividends and 7.5% on interest and royalties, sets a 183-day test for employment income, and makes the country of residence credit tax paid in the other. It covers income tax and capital gains tax in both countries.
The South Africa-Nigeria double tax agreement decides which country may tax income that crosses between them, caps the tax Nigeria or South Africa can withhold at source on dividends, interest and royalties, and requires the country of residence to give a credit for tax paid in the other. It was signed in Cape Town on 29 April 2000 and entered into force on 5 July 2008, according to SARS's notice in Government Gazette 31241 of 22 July 2008. It covers income tax and capital gains tax on both sides. This is information, not tax advice.
Which taxes it covers
- Nigeria
- Personal income tax, companies income tax, petroleum profits tax, capital gains tax and education tax (Article 2).
- South Africa
- Normal tax and secondary tax on companies (Article 2), as listed when signed.
- When it applies
- For withholding taxes, to amounts paid on or after 1 January following entry into force; for other taxes, to years of assessment or basis periods beginning on or after that date (Article 27).
Withholding limits
| Income | Treaty cap at source | Article |
|---|---|---|
| Dividends, company holding 10% or more | 7.5% | 10 |
| Dividends, all other cases | 10% | 10 |
| Interest | 7.5% | 11 |
| Royalties | 7.5% | 12 |
| Interest paid to the other government, the CBN or the SARB | Exempt at source | 11(3) |
The interest and royalty rates are hard to read in the scanned gazette copy; PwC's Nigeria withholding tax summary (reviewed May 2026) lists 7.5% for dividends, interest and royalties under the South Africa treaty, against a Nigerian domestic rate of 10% on dividends and interest. A treaty rate is a cap: it applies only where the domestic rate is higher.
Employment, pensions and students
- Employment (Article 15). Pay for work done in the other country can be taxed there. It stays taxable only in your country of residence if you are present in the other country for no more than 183 days in any twelve-month period, your employer is not resident there, and the pay is not borne by a branch there.
- Self-employed work (Article 14). Taxable only where you live, unless you have a fixed base regularly available in the other country; more than 183 days there in any twelve months is treated as having one.
- Directors' fees (Article 16). May be taxed where the company is resident.
- Pensions (Article 18). Pensions and annuities arising in one country and paid to a resident of the other may be taxed in the country where they arise.
- Government pay (Article 19). Generally taxed only by the paying government.
- Students (Article 20). Payments from abroad for maintenance, education or training are exempt in the host country.
Property and capital gains
Under Article 13, a gain on immovable property, such as a house in Lagos, may be taxed in the country where the property is. Gains on other property, including shares, are taxable in the seller's country of residence.
How the credit works
Article 22 removes the double charge. A South African resident who pays Nigerian tax on Nigerian income deducts it from the South African tax on the same income, up to the share of South African tax that income bears. Nigeria gives a credit for South African tax on South African-source income, subject to Nigerian law.
Example only. A South African resident earns income in Nigeria that bears ₦100,000 of Nigerian withholding tax. If the South African tax on the same income, converted to rand, is higher than the Nigerian tax, SARS allows the Nigerian tax as a credit and the resident pays only the difference. If the Nigerian tax is higher, the credit is limited to the South African tax on that income.
Who you are resident in
If both countries treat you as resident, Article 4 breaks the tie in this order: where you have a permanent home, then your centre of vital interests, then your habitual abode, then nationality. If that does not settle it, the two tax authorities decide. Disputes go to the mutual agreement procedure, and Article 24 requires a case to be presented within three years of the first notification of the tax in question.
Claiming the treaty rate in Nigeria
FIRS Information Circular 2022/15, now under the Nigeria Revenue Service, says a non-resident claiming a reduced treaty rate submits a certificate of residence endorsed by the home tax authority, a letter to the Executive Chairman and evidence of the income, plus a beneficial owner declaration. For a South African resident, the home tax authority is SARS.
Where Pryme fits
Keeping clean records of what you earned and paid in each country makes treaty claims easier. Pryme lets any customer generate a regular or verifiable statement through verifiable receipts. Read SARS foreign tax credits for Nigerian tax, getting a SARS certificate of residence and, for comparison, the UK-Nigeria treaty.
Questions people ask
Does South Africa have a double tax agreement with Nigeria?
Yes. It was signed on 29 April 2000 and entered into force on 5 July 2008, per Government Gazette 31241.
What is the withholding tax on Nigerian dividends for a South African resident?
The treaty caps it at 7.5% for a company holding at least 10%, and 10% in other cases.
Do I pay tax twice on Nigerian rent while living in SA?
Nigeria may tax the rent, and SARS gives a credit for the Nigerian tax up to the SA tax on that income.
How many days can I work in Nigeria without Nigerian tax?
Under Article 15, pay stays taxable only in SA if you are there no more than 183 days in any 12 months and other conditions are met.
Sources
- Government Gazette 31241: Agreement between South Africa and Nigeria for the avoidance of double taxation · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, corporate withholding taxes · accessed Oct 2026
- FIRS Information Circular 2022/15 on claiming tax treaty benefits (KPMG copy) · accessed Oct 2026
- Clearstream: Double taxation treaties concluded by South Africa · 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.