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The short answer
Yes. Spain and Nigeria have a full double tax convention, signed in Abuja on 23 June 2009, published in the BOE on 13 April 2015 and in force from 5 June 2015. It covers income tax, corporation tax and capital gains tax, caps Nigerian withholding on interest at 7.5% and on dividends at 10% for individuals, and makes your country of residence credit tax paid in the other.
The treaty in one paragraph
Spain and Nigeria have a full income tax convention, not a partial one. It was signed in Abuja on 23 June 2009, published in Spain's Boletín Oficial del Estado on 13 April 2015 and, according to the published text, entered into force on 5 June 2015. For taxes charged by period, such as income tax, it applies to tax years beginning on or after that date. The Ministerio de Hacienda publishes the BOE text in Spanish and English on its list of treaties, and Nigeria's own list of treaties in force (FIRS Information Circular 2022/15) includes Spain.
The convention does two jobs. It decides which country may tax each kind of income, and it obliges the country where you live to give relief for tax paid in the other. It does not stop you filing in either country, and it does not make income tax-free just because it has been taxed once somewhere.
Which taxes it covers
Article 2 lists the taxes. On the Spanish side: personal income tax (IRPF), corporation tax, income tax on non-residents, wealth tax and local taxes on income and capital. On the Nigerian side: Personal Income Tax, Companies Income Tax, Petroleum Profits Tax, Capital Gains Tax and Education Tax. Taxes introduced later that are identical or substantially similar are covered too, which matters because Nigeria reorganised its tax laws under the Nigeria Tax Act 2025 and its collector is now the Nigeria Revenue Service (NRS), which replaced FIRS.
Who may tax what: the main articles
| Income | Article | What the treaty says |
|---|---|---|
| Rent and gains on Nigerian land or buildings | 6 and 13(1) | Nigeria may tax, because the property is there. Spain may also tax its residents and must give relief. |
| Salary | 15 | Taxed where you live unless the work is done in the other country. Short visits are protected if you are there no more than 183 days in any 12 months, your employer is not resident there and no branch there bears the pay. |
| Dividends | 10 | Source country capped at 7.5% for a company holding at least 10% directly; 10% in all other cases, including individuals. |
| Interest | 11 | Source country capped at 7.5%; interest paid to the other government or its central bank is exempt at source. |
| Royalties | 12 | 7.5% where the owner is a company; 3.75% in other cases. |
| Private pensions | 18 | Only the country where you live may tax pensions for past employment (government pensions follow Article 19). |
| Shares in property-rich companies | 13(4) | Where more than 50% of the value comes from immovable property in the other country, that country may tax the gain. |
| Freelance work | 14 | Taxed where you live unless you have a fixed base regularly available in the other country. |
Two practical points follow. First, for an individual receiving Nigerian dividends, the treaty cap is 10%, which PwC's Nigeria withholding tax summary (reviewed May 2026) gives as the domestic rate anyway, so the treaty adds little there. Second, the interest and royalty caps sit below the domestic rates PwC lists (10% on interest; 5% on royalties paid to individuals), so the treaty does reduce Nigerian withholding on those, but only if you claim it.
How double tax is relieved
Article 24 lets each country relieve double tax either under its own law or under the treaty. Under the treaty method, the country of residence deducts from its own tax an amount equal to the income tax paid in the other country, but never more than the part of its own tax that relates to that income. If the treaty exempts income in the country of residence, that country may still count it when setting the rate on the rest (exemption with progression). In Spain the relief is claimed in the Renta as the deduction for international double taxation; we explain the mechanics in claiming credit in Spain for Nigerian tax.
Worked example (illustrative figures)
A Spanish resident earns Nigerian bank interest worth €1,000. Without a treaty claim, Nigeria withholds 10%, or €100. With a valid treaty claim the Nigerian charge is capped at 7.5%, or €75. Suppose Spanish tax on that €1,000 works out at €190 (an example figure, not a rate). Spain credits the Nigerian tax up to €190, so on the treaty claim the credit is €75 and Spain collects €115. Total tax stays €190 either way; the treaty claim simply moves €25 of it from Nigeria to Spain, and Spain may refuse to credit Nigerian tax charged above the treaty rate, so failing to claim can cost you that €25.
The protocol: three clauses to know
- Anti-abuse. Domestic anti-avoidance rules apply, benefits go only to beneficial owners, and arrangements made mainly to obtain treaty benefits are refused.
- Most-favoured nation. If Nigeria later agrees a lower rate or an exemption on dividends, interest or royalties with an OECD member, Spanish residents get the same benefit.
- Remittance. Where relief depends on income being taken into the country of residence, the protocol allows the claim if the income is remitted to Nigeria within four years, or to Spain within six years, of payment, on the taxpayer's request.
What to check first
- Confirm which country you are resident in for the year; if both claim you, Article 4 breaks the tie (permanent home, then centre of vital interests, then habitual abode, then nationality).
- For Nigerian interest, royalties or dividends, ask the payer what it needs to apply the treaty rate. The FIRS circular asks for a certificate of residence endorsed by your home tax authority and a letter to the tax authority's chairman.
- Keep Nigerian withholding tax receipts; you need them for the Spanish credit.
- If you think a country has taxed you against the treaty, a mutual agreement case must be presented within three years of the first notification of that tax (Article 26).
Where Pryme fits
Pryme lets you hold naira and euros in one account, so Nigerian interest or rent can stay in naira until you choose to convert with Swap, where the app shows the rate and the fee before you approve. Verifiable statements from Pryme receipts help when Spain asks for proof of Nigerian income. Naira deposits are held by a licensed Nigerian microfinance bank; outside Nigeria, Pryme works through regulated partners. See multicurrency accounts.
Questions people ask
Is there a tax treaty between Spain and Nigeria?
Yes. The convention was signed on 23 June 2009, published in the BOE on 13 April 2015 and entered into force on 5 June 2015, according to the published text.
What is the Nigerian withholding tax rate on interest for Spanish residents?
The treaty caps it at 7.5% of the gross interest, against a 10% domestic rate. You must claim the treaty rate with the paperwork the payer and NRS ask for.
Does the treaty stop Nigeria taxing my Lagos rent?
No. Article 6 lets Nigeria tax income from property in Nigeria. Spain then taxes you as a resident and gives a credit for the Nigerian tax, up to the Spanish tax on that income.
Who taxes my Nigerian pension if I live in Spain?
Article 18 gives private pensions for past employment to the country where you live. Government service pensions follow Article 19, which generally leaves them with the paying country.
Sources
- Spain–Nigeria Convention for the avoidance of double taxation and Protocol (English text published by the Ministerio de Hacienda) · accessed Oct 2026
- Convenio entre el Reino de España y la República Federal de Nigeria para evitar la doble imposición, y Protocolo (BOE 13 Apr 2015; Ministerio de Hacienda copy, Spanish) · accessed Oct 2026
- Ministerio de Hacienda: Convenios para evitar la doble imposición, alphabetical list (Nigeria entry 13/04/15) · accessed Oct 2026
- FIRS Information Circular 2022/15: Claim of tax treaty benefits in Nigeria (11 May 2022, KPMG-hosted copy) · 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.