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The short answer
If Nigeria and the country you live in both treat you as tax resident, a double tax treaty between them decides where you are resident for treaty purposes, testing in order: permanent home, centre of vital interests, habitual abode, nationality, then agreement between the two tax authorities. The UK and Canada treaties with Nigeria use this order. Where no treaty exists, as with the United States, there is no tie-breaker: both countries can tax you as a resident and relief comes only through foreign tax credits.
Most Nigerians abroad assume that once they have moved, Nigeria stops treating them as resident. Under the Nigeria Tax Act 2025 that is not safe to assume. The tests are broad, and some of them have nothing to do with how many days you spend in Lagos.
Why dual residence happens
PwC's Nigeria residence summary (reviewed 29 May 2026) says an individual is resident if any one of these applies, and non-resident only if none does:
- domiciled in Nigeria;
- a permanent home available for domestic use in Nigeria;
- a place of habitual abode in Nigeria;
- at least 183 days in Nigeria in any 12-month period, including temporary absences;
- substantial economic ties or immediate family ties in Nigeria;
- serving as a Nigerian diplomat abroad.
A Mondaq analysis (27 October 2025) points out that the Act's list joins economic and family ties with "and" while commentators read it as "or", and that neither term is defined. So a nurse in Birmingham who keeps a furnished flat in Abuja, or whose spouse and children remained in Nigeria, could meet a Nigerian test while being fully UK resident under the UK's own statutory residence test. Our guide on long visits and the 183-day test covers the day-count side.
How a treaty tie-breaker works
Where both countries claim you, the treaty's residence article decides which one counts as your residence for the treaty. The UK–Nigeria agreement (Article 4(2)) and the Canada–Nigeria agreement (Article 4(2)) apply the same sequence, stopping at the first test that gives a clear answer:
- Permanent home. You are resident where you have a permanent home available to you. If you have one in both countries, move on.
- Centre of vital interests. The country with which your personal and economic relations are closer: family, job, business, social life.
- Habitual abode. Where you usually live, judged by time spent over a period.
- Nationality. The country of which you are a national. Dual nationals of both countries pass to the last step.
- Mutual agreement. The two tax authorities settle the case between them.
Example (illustration only)
Chidi works full time for an NHS trust in Leeds, rents a flat there with his wife and children, and owns a house in Enugu kept furnished for visits. Nigeria could treat him as resident because the Enugu house is a permanent home available to him; the UK treats him as resident under its own rules. Both countries have a permanent home available, so the first test does not decide. His job, his family and his daily life are in Leeds, so his centre of vital interests is the UK. For the treaty he is UK resident, and Nigeria taxes him only as the treaty allows a source country to, for example on rent from the Enugu house.
What the result changes, and what it does not
Winning the tie-breaker does not make Nigerian income tax-free. It decides which country is the "residence" state and which is the "source" state for each type of income. In the UK treaty, Nigeria can still tax rent from Nigerian property (Article 6), and dividends and interest within the treaty limits (Articles 10 and 11); the UK, as residence state, gives credit for that Nigerian tax (Article 22). Our guide to the UK–Nigeria treaty walks through each article.
To rely on the treaty in Nigeria you usually need proof of residence from your home tax office. A 2022 Nigerian tax authority circular on treaty claims asks for a certificate of residence endorsed by the tax authority of the country of residence.
Where there is no treaty
Nigeria has comprehensive treaties with only a short list of countries; our treaty list sets them out. The IRS's A to Z list of US income tax treaties (updated January 2026) has no entry for Nigeria, and PwC's Nigeria treaty list (May 2026) does not include Ireland. Without a treaty:
- there is no tie-breaker, so each country applies its own residence rules and both may tax your worldwide income;
- relief comes from domestic rules, usually a credit for foreign tax paid on the same income (see how double tax is relieved without a treaty);
- for a Nigerian resident, PwC says Nigeria gives a unilateral credit capped at the lower of the Nigerian tax on that income and the foreign tax paid.
Steps if you think you are resident in both
- Test yourself against each Nigerian residence condition carefully, especially permanent home and family ties.
- Check whether your country has a treaty with Nigeria in force.
- If it does, work through the tie-breaker in order and keep evidence (tenancy, employment contract, family addresses).
- Ask your home tax office for a certificate of residence if a Nigerian payer or the NRS needs one.
- If there is no treaty, plan for foreign tax credits and keep every Nigerian tax receipt.
This is information, not tax advice. Residence cases turn on facts, and a cross-border adviser should review yours.
Questions people ask
Can I be tax resident in Nigeria and the UK at the same time?
Yes. Each country applies its own rules, and Nigeria's are broad. The UK–Nigeria treaty tie-breaker then decides which country counts as your residence for the treaty.
Does keeping a house in Nigeria make me Nigerian tax resident?
It can. A permanent home available for domestic use is one of the Nigeria Tax Act tests, and any one test is enough.
Is there a tax treaty between Nigeria and the US?
No. The IRS treaty list has no Nigeria entry, so there is no tie-breaker; relief relies on foreign tax credits.
What is centre of vital interests?
The country with which your personal and economic relations are closer: where your family, job and business life are. It is the second treaty test, used when you have a permanent home in both countries.
Sources
- PwC Worldwide Tax Summaries: Nigeria, individual residence (reviewed 29 May 2026) · accessed Oct 2026
- Mondaq (S.P.A. Ajibade & Co): Individual tax residency under the tax reform Acts (27 Oct 2025) · accessed Oct 2026
- GOV.UK: 1987 UK–Nigeria double taxation agreement · accessed Oct 2026
- Canada–Nigeria tax agreement text · accessed Oct 2026
- IRS: United States income tax treaties A to Z (updated 3 Jan 2026) · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, foreign tax relief and tax treaties (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.