Section 6 Nigeria Tax Act 2025

Section 6 of the Nigeria Tax Act 2025 is about Nigerian company. It provides as follows:

(1) The profits of a Nigerian company are deemed to accrue in Nigeria wherever the profits arise and whether or not such profits have been brought into or received in Nigeria.

(2) Where a foreign company which is controlled by a Nigerian company has not, in a year, distributed profits to its shareholders, the proportion of the profits of the controlled foreign company attributable to the Nigerian company, which could have been distributed without detriment to the company’s business shall be construed as distributed and included in the profits of the Nigerian company for the purposes of subsection (1).

(3) Where the income tax paid by a non-resident company which is a subsidiary of a Nigerian company or a member of a multinational group of a Nigerian company in any year yields less than the minimum effective tax rate prescribed by this Act, the Nigerian parent company shall pay an amount to make that non-resident subsidiary’s income tax equal to the minimum effective tax rate.

(4) The Service shall provide detailed rules for the implementation of subsections (2) and (3).

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