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
A UK-incorporated company stays UK tax resident under HMRC's incorporation rule even if its director moves to Nigeria. But section 201 of the Nigeria Tax Act 2025 treats a company whose central or effective place of management or control is in Nigeria as a Nigerian company, so a company run from Lagos can be resident in both, and the UK-Nigeria treaty leaves that to the two tax authorities to agree.
Two tests that look at different things
The UK and Nigeria start from different points. The UK has an incorporation rule: HMRC's International Manual (INTM120060, updated 20 October 2026) says the older central management and control test now matters only for companies not incorporated in the UK, and for UK-incorporated companies within an exception to the incorporation rule. Nigeria, under the Nigeria Tax Act 2025, looks at management. KPMG Nigeria says section 201 defines a Nigerian company as one formed or registered in Nigeria, or whose central place of management or control is in Nigeria, or whose effective place of management or control is in Nigeria.
So the UK rule does not protect you from the Nigerian one. A director who moves to Lagos and keeps running the UK company alone may leave it UK resident and Nigerian resident at the same time.
What "central management and control" means
Although the UK no longer relies on it for its own companies, the UK case law is the best guide to how management tests work, and KPMG notes Nigeria's Act does not define "management or control". HMRC's manual draws on these cases:
- De Beers v Howe
- A company resides where its real business is carried on, which is where "the central management and control actually abides". A South African company whose board acted in London was UK resident.
- Bullock v Unit Construction (1959)
- Subsidiaries' boards were meant to meet abroad, but the directors stood aside on everything important and the UK parent's board really controlled them; they were UK resident.
- Union Corporation v CIR (1953)
- A company can be resident wherever acts of controlling power are exercised "to a substantial degree", so dual residence is possible.
HMRC treats the place of control as a question of fact, focused on the highest level of control of the business. Paper arrangements that do not match what happens do not decide it.
What dual residence can cost
KPMG says a company treated as Nigerian may be subject to Companies Income Tax at 30% on its worldwide income, a 4% development levy and withholding taxes, with foreign tax credits under section 119(1) as possible relief. The UK still charges Corporation Tax on the same profits. Credits can reduce double tax, but they bring two sets of returns, two sets of advisers and arguments over who taxes first.
The treaty does not settle it automatically
Many modern treaties use a place of effective management tie-breaker. The 1987 UK-Nigeria agreement does not. Article 4(3) says that where a person other than an individual is resident in both states, the competent authorities settle the question by mutual agreement. In practice you would have to ask HMRC and the Nigeria Revenue Service to agree, which takes time and has no fixed outcome.
Worked example
Example: Chiamaka owns 100% of a UK software company with £120,000 profit. She moves to Lagos, remains the sole director, signs every contract and hires staff from there. Under the incorporation rule the company is still UK resident. Under section 201, it may also be Nigerian because its control is exercised in Lagos. If Nigeria assessed it at 30% on the same profit, the headline Nigerian charge would be £36,000 before any credit for UK tax, and both authorities would need to be dealt with.
Compare her colleague Emeka, who moves to Abuja but keeps a UK-resident co-director who runs operations, holds quarterly board meetings in London where pricing, hiring and funding are decided, and keeps contracts signed in the UK. His position is easier to defend, though not risk-free.
Steps that reduce the risk
- Map who makes the big decisions: strategy, funding, major contracts, hiring senior staff.
- If you want the company to stay only UK resident, make sure those decisions are really taken in the UK by people there, and minute where and how.
- Do not let a UK director stand aside on everything important; Bullock shows that does not work.
- If the business is moving to Nigeria for good, consider a Nigerian company (see setting up a Nigerian subsidiary) rather than stretching the UK one.
- Take advice in both countries before the move, not after an assessment.
Residence is one risk; a permanent establishment is another. Even a company that is only UK resident can have a taxable presence in Nigeria through an office or a place of management under Article 5 of the treaty. See whether a UK company can create a taxable presence in Nigeria and keeping your UK company after the move.
Where Pryme fits
Pryme does not decide where a company is resident. What it can do is keep the money side tidy. Business accounts come with a Chief of Staff and Finance agents that prepare work and record every action, and a person approves above a set ceiling, which gives you a clear record of who approved what and when. See Chief of Staff and Finance. This is information, not tax advice.
Questions people ask
Is my UK company still UK resident if I run it from Nigeria?
For UK tax, a UK-incorporated company normally stays UK resident under the incorporation rule, as HMRC's manual describes.
Can Nigeria tax my UK company?
It may. Section 201 of the Nigeria Tax Act 2025 treats a company with its central or effective place of management or control in Nigeria as a Nigerian company, according to KPMG Nigeria.
What does the UK-Nigeria treaty say about dual resident companies?
Article 4(3) leaves it to the two tax authorities to settle by mutual agreement. There is no automatic tie-breaker.
Does holding board meetings in London help?
It can, if the real decisions are made there. HMRC treats control as a question of fact, so meetings that only rubber-stamp decisions made in Lagos may not help.
Sources
- HMRC International Manual INTM120060: company residence, central management and control (updated 20 Oct 2026) · accessed Oct 2026
- Mondaq (KPMG Nigeria): Place of effective management and control under the Nigeria Tax Act (23 Jan 2026) · accessed Oct 2026
- GOV.UK: 1987 UK-Nigeria double taxation agreement, in force · 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.