AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
When a Spanish SL charges a related Nigerian company for services, management or software, both countries expect the price to be what independent parties would agree (arm's length), backed by a written agreement, invoices and evidence the service was delivered. On the Nigerian side, connected-party management and technical fees must meet Nigeria's transfer pricing rules to be deductible, and the payer generally withholds 10% tax on such fees to a non-resident company.
Why intercompany charges get scrutiny
Founders who run a Spanish SL and a Nigerian company often move money between them informally: Spain pays a developer, Lagos covers an office, someone settles up at year end. Tax authorities on both sides look for one thing in those flows: whether profit has been shifted to where tax is lower. The defence is a charge set at an arm's-length price, the price unrelated businesses would agree for the same service, with documents to show it.
What Nigeria expects
PwC's Nigeria corporate deductions summary (reviewed May 2026) sets out the rules that bite on intercompany charges:
- Royalties, management fees and technical fees paid to connected parties must conform to Nigeria's transfer pricing regulation to be deductible.
- Interest paid to connected parties is limited to 30% of EBITDA, including guaranteed local or foreign debt, with the excess carried forward for up to five years.
- Artificial or fictitious payments are not deductible.
Withholding tax applies too. PwC's withholding tax table (May 2026) shows 10% on commission, consultancy, technical, management and professional fees paid to a non-resident company, and notes that withholding is a final tax for non-resident providers of technical, professional, management and consultancy services. For related-party transactions, the duty to deduct arises at the earlier of payment or when the liability is recognised in the books, and the tax is filed by the 21st. Spain is among the treaty countries with a reduced 7.5% rate on dividends, interest and royalties; a royalty for software may therefore be taxed differently from a management fee. Claiming a treaty rate in Nigeria requires a Spanish certificate of residence and a letter to the tax authority, as the FIRS circular on treaty claims describes.
The Nigeria library covers this in more depth in Nigerian withholding tax for non-resident companies.
What Spain expects
Spain applies the same arm's-length principle to transactions between related entities, and the SL must be able to show how it set the price. The documentation burden is lighter for smaller groups than for multinationals, and an informative return on related-party transactions may apply above set amounts. Your asesor will confirm what your SL has to prepare for its size; do not assume that a two-company family group is exempt from everything.
On VAT, a service the SL supplies to a Nigerian business is generally reported in Spain as a non-subject operation in box 120 of Modelo 303, according to AEAT's 2026 instructions. In Nigeria, PwC notes a reverse charge where services are bought without a Nigerian VAT invoice, so the Nigerian company may need to account for Nigerian VAT on what it receives from you.
A worked example
Illustrative only. A Madrid SL provides finance and marketing support to its Lagos sister company and charges a management fee equivalent to €8,000 for the year, based on cost plus a mark-up that a benchmarking review supports.
| Step | Amount |
|---|---|
| Fee invoiced by the SL | €8,000 |
| Nigerian WHT on a management fee to a non-resident company (10%) | €800, deducted by the Lagos company and paid to the Nigerian tax authority |
| Cash received by the SL | €7,200 |
| Deductible in Nigeria? | Only if the fee meets the transfer pricing rules and the service is evidenced |
Ask your Spanish asesor how the €800 of Nigerian tax is treated in the SL's corporate tax return; the answer depends on the treaty and on Spanish rules for foreign tax.
The paper trail both sides want
- A signed intercompany agreement describing the services, the pricing method and payment terms.
- A note on how the price was set (cost plus a mark-up, hourly rates, comparable prices) and who reviewed it.
- Invoices in the agreed currency, numbered and issued on time, with matching entries in both companies' books.
- Evidence of delivery: reports, timesheets, emails, meeting notes.
- Withholding tax receipts or credit notes from Nigeria, and any residence certificates used for treaty rates.
- Bank records that match each invoice to a payment.
Settling intercompany balances
Charges are only half the story; the balances must be settled too. Intercompany invoices that sit unpaid for years look less like a commercial arrangement and more like a disguised loan, and connected-party interest has its own limits in Nigeria, as PwC notes. Agree payment terms in the intercompany agreement, settle on those terms, and if one company is in fact lending to the other, document it as a loan with an arm's-length interest rate rather than leaving an open invoice.
Where Pryme fits
A Pryme Business Account for each company keeps euro and naira flows visible, and Invoicing issues numbered intercompany invoices. The Finance agent prepares the matching of invoices to payments and withholding credits for a person to approve, and verifiable statements help when an auditor asks for proof. See also setting up a Nigerian subsidiary from a Spanish SL and keeping books in euros and naira.
Questions people ask
Can my Spanish SL charge my Nigerian company a management fee?
Yes, if the fee reflects a real service at an arm's-length price and is documented. In Nigeria, connected-party management fees must meet the transfer pricing rules to be deductible.
What withholding tax applies to management fees paid from Nigeria to Spain?
PwC shows 10% on management, technical and consultancy fees paid to a non-resident company, as a final tax, as at May 2026.
Does the Spain–Nigeria treaty reduce withholding?
PwC lists Spain among countries with a 7.5% treaty rate on dividends, interest and royalties. Claiming it needs a Spanish certificate of residence filed with the Nigerian tax authority.
Is there a limit on interest charged to a Nigerian related company?
Yes. Connected-party interest is deductible only up to 30% of EBITDA, with the excess carried forward for up to five years (PwC).
Sources
- PwC Worldwide Tax Summaries: Nigeria, corporate deductions (reviewed 29 May 2026) · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, withholding taxes (reviewed 29 May 2026) · accessed Oct 2026
- FIRS Information Circular 2022/15 on claiming tax treaty benefits (11 May 2022, KPMG copy) · accessed Oct 2026
- Agencia Tributaria: Modelo 303, instrucciones ejercicio 2026 (page updated 9 Jun 2026) · accessed Oct 2026
- PwC Worldwide Tax Summaries: Nigeria, other taxes (corporate, 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.