Asked about Nigerian Companies Income Tax (CIT) for a resident Nigerian company.
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Small company (turnover ≤ ₦50M and fixed assets ≤#250M) — CIT rate
Exempted from CIT, CGT and 4% development feeNIGERIAN TAX ACT 2025
Medium company (₦100M–₦500M) — CIT rate
20% plus 4% development levyNIGERIAN TAX ACT 2025
Large company (> ₦500M turnover) — CIT rate
30% plus 4% development levyNIGERIAN TAX ACT 2025
Tertiary Education Tax (TET) rate
A new 4% levy on assessable profit replaces multiple levies (TET, NASENI, PTF, IT LEVY) from 1st january 2026NIGERIAN TAX ACT 2025
Minimum tax (where CIT < minimum)
15% minimum effective tax rate (ETR) targeted at large corporations and multinationals enterprises (MNEs)NIGERIAN TAX ACT 2025
CIT return filing deadline
6 months after accounting year end or 18 months from incorporation for new companiesNIGERIAN TAX ACT 2025
Initial allowance — plant & machinery
10% Category: Assets in this bracket generally include buildings, infrastructure, and long-term structures.20% Category: Assets in this bracket typically cover industrial equipment, furniture, and heavy machinery (e.g., qualifying petroleum rights are also set at 20%).25% Category: Assets in this bracket apply to fast-depreciating property like motor vehicles, computers, and office technology
Produced by OpenAccountants (openaccountants.com)
This skill is for informational purposes only and does not constitute tax, legal, or financial advice. All outputs must be reviewed and signed off by a Nigerian chartered tax practitioner (ICAN / ANAN / CITN) before filing or acting upon.
Reviewed against the cited tax authorities by Omolola Fasasi on 2026-06-21. Items flagged for further clarification are tracked separately and excluded here. This block is generated from verified
skill_facts— edit the facts, not the prose.
Quick reference field table
| Field | Value |
|---|---|
| Country | Federal Republic of Nigeria |
| Tax | Companies Income Tax (CIT) |
| Currency | NGN (Naira) — ₦ |
| Tax year | Accounting year of the company (any 12-month period; first/final years may be shorter) |
| Primary legislation (2025) | Companies Income Tax Act, Cap. C21 LFN 2004, as amended by Finance Acts 2019–2023 |
| Primary legislation (2026+) | Nigeria Tax Act 2025 (NTA 2025) — signed by President Tinubu 26 June 2025; effective 1 January 2026 |
| Tax authority | FIRS — Federal Inland Revenue Service |
| Filing portal | FIRS Tax Pro-Max (taxpromax.firs.gov.ng) |
| Annual return deadline | 6 months after accounting year-end (Section 55 CITA / equivalent NTA 2025) |
| Payment | With return, or in instalments up to filing deadline (FIRS approval) |
| Bookkeeping retention | 6 years (Section 63 CITA); align with NTA 2025 implementing regulations |
| Skill version | 1.0 |
| Validated by | Verified by Omolola Fasasi (MB058950) on 2026-06-21 |
Legacy CITA 2025 rate table
| Company size | Definition | CIT rate |
|---|---|---|
| Small | Turnover ≤ ₦25M (CITA s.40 as amended Finance Act 2019) | 0% |
| Medium | ₦25M < Turnover ≤ ₦100M | 20% |
| Large | Turnover > ₦100M | 30% |
| Tertiary Education Tax (TET) | All companies except small | 3% of assessable profit (Tertiary Education Trust Fund Act) |
| NITDA levy | Companies with turnover ≥ ₦100M in specified sectors | 1% of profit before tax |
| NASENI levy | Companies with turnover ≥ ₦100M in specified sectors | 0.25% of profit before tax |
| Police Trust Fund levy | All companies | 0.005% of net profit |
NTA 2025 rate table (from 1 January 2026)
| Company size | Definition (NTA 2025) | CIT rate |
|---|---|---|
| Small | Turnover ≤ ₦100M AND fixed asset base ≤ ₦250M | 0% |
| Medium | ₦100M < Turnover ≤ ₦1B | 20% |
| Large | Turnover > ₦1B | 30% in 2026, transitioning to ~25% by 2029 via tax-credit mechanism per NTA 2025 transitional schedule |
| Development Levy (unified) | All non-small companies | 2% of assessable profit — replaces TET, NITDA, NASENI, and Police Trust Fund levies |
| Minimum Effective Tax Rate (MET) | Multinational groups with consolidated revenue > €750M | 15% floor (Pillar Two GloBE alignment) |
TBC — verify under NTA 2025 final implementing regulations: the precise 2026-2029 large-company phasing schedule, the exact MET top-up mechanics, and the final Development Levy allocation formula are subject to FIRS implementing regulations expected late 2025 / early 2026.
Conservative defaults table
| Ambiguity | Default |
|---|---|
| Accounting period spans 1 Jan 2026 (CITA-to-NTA transition) | Apportion on a daily basis; apply legacy rules to pre-2026 portion, NTA 2025 to post-2026 portion |
| Company size band unknown | Large (30% + 2% Development Levy) |
| Asset base unknown for NTA 2025 small-company test | Assume > ₦250M (small-company status denied) |
| Pillar Two MET applicability unclear | Treat as in-scope if any group entity is in a jurisdiction with consolidated revenue > €750M |
| Capital allowance claim unsupported | Disallow until asset-register evidence is produced |
| Loss carry-forward year unknown | Verify per-year schedule; treat oldest losses as expired under legacy 4-year limit if pre-Finance Act 2019 |
| Pioneer status / IDITR relief uncertified | Apply standard rate; flag pending Industrial Inspectorate certificate |
| TIN status unknown | Halt — TIN is mandatory before filing |
Minimum viable — Audited or management financial statements (income statement, balance sheet) for the accounting year, prior-year CIT computation, TIN, accounting-year-end date, and confirmation of (i) turnover band, (ii) total fixed asset base, (iii) whether any group entity triggers Pillar Two scoping.
Recommended — Trial balance, general ledger, fixed-asset register (acquisition cost, date in use, location), schedule of capital additions and disposals, prior-year capital allowances brought forward, loss memo, tax credit certificates (WHT credit notes), donation receipts.
Ideal — Audited statements signed by a chartered accountant (ICAN), full WHT credit reconciliation, FIRS clearance certificates, group structure chart, transfer-pricing documentation if applicable, and prior year FIRS assessment notices.
HARD STOP if minimum is missing. Without financial statements and the prior-year return, no CIT computation may be produced.
ng-income-tax. VAT → ng-vat-return / nigeria-vat. This skill is corporate income tax only.TBC — verify under NTA 2025 final implementing regulations. Indicative trajectory pending FIRS schedule:
Large-company rate phasing table
| Accounting year | Headline rate | Tax-credit reduction | Effective rate (approx.) |
|---|---|---|---|
| 2026 | 30% | TBC | ~28-30% |
| 2027 | 30% | TBC | ~27% |
| 2028 | 30% | TBC | ~26% |
| 2029 onward | 30% | TBC | ~25% |
TBC — verify under NTA 2025 final implementing regulations: the precise allocation formula between TETFund, NITDA, NASENI, Defence Security Trust Fund, Police Trust Fund, and other beneficiaries; and the transition treatment for accounting years straddling 1 January 2026.
TBC — verify under NTA 2025 final implementing regulations: the precise top-up mechanism (Domestic Top-up Tax / Qualified Domestic Minimum Top-up Tax — QDMTT), the Income Inclusion Rule (IIR), Undertaxed Payments Rule (UTPR) sequencing, and the carve-out / safe-harbour rules expected to mirror OECD model rules.
Capital allowance rates per asset class (Second Schedule CITA / Sixth Schedule NTA 2025)
| Asset class | Initial allowance | Annual allowance |
|---|---|---|
| Building (industrial) | 15% | 10% |
| Building (non-industrial) | 15% | 10% |
| Furniture and fittings | 25% | 20% |
| Motor vehicle | 50% | 25% |
| Plant and machinery — agricultural | 95% | nil (effectively 100% Year 1) |
| Plant and machinery — industrial | 50% | 25% |
| Plant and machinery — other | 50% | 25% |
| Computers (hardware) | 50% | 25% |
| Software | 50% | 25% |
| Research & development | 95% | nil (full Year 1 for approved R&D) |
TBC — verify under NTA 2025 Sixth Schedule final text whether any rate has been revised. Conservative default: apply the legacy CITA Second Schedule rates pending confirmation.
Restrictions:
TBC — verify under NTA 2025 final implementing regulations whether 0.5% of turnover is retained, replaced, or subsumed into the MET framework.
TBC — verify under NTA 2025 whether retained.
All examples assume calendar accounting year ending 31 December 2025 (legacy CITA) unless stated.
Facts: ABC Ltd. Turnover ₦18,000,000. Accounting profit ₦4,500,000.
Small company test: Turnover ₦18M ≤ ₦25M → Small
CIT : 0% → ₦0
TET : Exempt → ₦0
NITDA : Below ₦100M threshold → ₦0
Police Trust Fund : 0.005% × accounting profit = ₦225 (de minimis)
Total tax payable : ₦225 (effectively ₦0 in practice)
Filing: ABC Ltd still files its CIT return on Tax Pro-Max within 6 months of year-end.
Facts: XYZ Ltd. Turnover ₦65,000,000. Adjusted profit ₦12,000,000. Capital allowances ₦2,000,000. No prior-year losses.
Assessable Profit : ₦12,000,000
Less Capital Allow. : (₦2,000,000)
Total Profit : ₦10,000,000
CIT (20% × Total Profit) : ₦2,000,000
TET (3% × Assessable Profit) : ₦360,000
Police Trust Fund (de minimis) : ₦60
Less WHT credits : (₦150,000) — WHT on professional fees
Net CIT payable : ₦2,210,060
Filing: return + payment by 30 June 2026 (6 months after year-end).
Facts: Big Co Plc. Turnover ₦5,400,000,000. Adjusted profit ₦820,000,000. Capital allowances ₦180,000,000. Loss b/f ₦40,000,000. WHT credits ₦26,000,000. Not in NITDA / NASENI specified sectors.
Assessable Profit : ₦820,000,000
Less Loss b/f : (₦40,000,000)
Less Capital Allow. : (₦180,000,000)
Total Profit : ₦600,000,000
CIT (30% × Total Profit) : ₦180,000,000
TET (3% × Assessable Profit) : ₦24,600,000
Police Trust Fund (0.005%) : ₦41,000 (on net profit)
Less WHT credits : (₦26,000,000)
Net CIT + levies payable : ₦178,641,000
Facts: Big Co Plc, accounting year 1 January – 31 December 2026. Turnover ₦5,400,000,000. Adjusted profit ₦820,000,000. Capital allowances ₦180,000,000. Loss b/f ₦40,000,000. WHT credits ₦26,000,000. Not in a multinational group above €750M.
Company size (NTA 2025): Turnover > ₦1B → Large
Assessable Profit : ₦820,000,000
Less Loss b/f : (₦40,000,000)
Less Capital Allow. : (₦180,000,000)
Total Profit : ₦600,000,000
CIT (30% × Total Profit, 2026 headline) : ₦180,000,000
Development Levy (2% × Assessable Profit) : ₦16,400,000 — replaces TET + NITDA + NASENI + PTF
MET top-up : n/a (group revenue < €750M)
Less WHT credits : (₦26,000,000)
Less NTA 2025 transitional tax credit : TBC under final regulations
Net CIT + Levy payable : ₦170,400,000 (before transitional credit)
Observations:
Form CIT components table
| Component | Content |
|---|---|
| CIT computation | Adjusted profit → Assessable profit → Total profit → Tax payable |
| Capital allowance schedule | Per asset class, qualifying capital expenditure, allowances, TWDV |
| Loss memo | Year of loss, amount, utilisation, balance c/f |
| TET / Development Levy computation | Per applicable regime |
| WHT credit schedule | WHT certificates, deducting party, amount |
| Transfer pricing declaration | If applicable |
| Audited financial statements | Signed by ICAN-licensed auditor |
| Schedule of donations | Recipient, amount, Fifth Schedule reference |
Filing deadlines table
| Item | Deadline |
|---|---|
| Annual CIT return | Within 6 months after end of accounting year (Section 55(2) CITA / NTA 2025) |
| Self-assessment payment | With return; or by instalments approved by FIRS, last instalment by filing deadline |
| Provisional / advance returns | Companies on PAYE-style advance payments: see FIRS taxpayer category rules |
| Pillar Two GloBE Information Return | TBC under NTA 2025 implementing regulations (likely 15 months after FY-end, OECD-aligned) |
| TP returns (declaration, disclosure) | With CIT return |
| CbCR | 12 months after end of reporting accounting year |
ng-income-tax. Companies are PAYE agents — they withhold and remit monthly by the 10th of the following month. This is administrative withholding, not CIT. (Personal Income Tax Act (PITA))All CIT returns are filed electronically via Tax Pro-Max (taxpromax.firs.gov.ng). The portal handles:
ng-vat-return)A valid Taxpayer Identification Number (TIN) issued by the Joint Tax Board / FIRS is mandatory.
Penalties and interest table
| Infraction | Sanction |
|---|---|
| Late filing of CIT return | ₦25,000 in first month + ₦5,000 each subsequent month (CITA / Finance Act updates) |
| Late payment | 10% penalty + interest at CBN MPR + 5% per annum (Section 32 FIRS Establishment Act 2007) |
| Failure to deduct / remit WHT | 10% of WHT due + interest |
| Incorrect return | Up to 100% of tax shortfall plus interest |
| Tax evasion / fraud | Fine up to ₦20,000 or 3× tax sought to be evaded, plus imprisonment up to 3 years |
TBC — verify under NTA 2025 final implementing regulations for any revisions to penalty quanta and interest mechanics.
Conservative defaults summary table
| Item | Default |
|---|---|
| Company size band unknown | Large (30% + 2% Development Levy or legacy levies) |
| Asset base unknown (NTA 2025) | > ₦250M (small status denied) |
| Accounting period straddles 1 Jan 2026 | Daily-apportion between CITA and NTA 2025 |
| Pillar Two MET applicability uncertain | Treat as in scope if any group entity is in a group with revenue > €750M |
| Pioneer status uncertified | Apply standard rate |
| Capital allowance evidence missing | Disallow until asset register provided |
| Loss carry-forward year uncertain | Schedule per-year; expire pre-2019 losses at 4 years if pre-Finance Act 2019 |
| Donation recipient not in Fifth Schedule | Disallow |
| Expense WREN test unclear | Disallow |
| WHT credit certificate missing | Disallow until certificate produced |
| Filing portal access uncertain | Confirm Tax Pro-Max enrolment before promising file dates |
| NTA 2025 figure not yet published | Label "TBC — verify under NTA 2025 final implementing regulations" |
Cross-references table
| Topic | Skill |
|---|---|
| Personal income tax / PAYE | ng-income-tax |
| VAT / value-added tax | ng-vat-return and nigeria-vat |
| Foundation principles | foundation |
| Intake checklist | intake |
| References / sources index | references |
When a topic spans skills (e.g., employee BIK with CIT deductibility and PAYE consequences), address both — load the cross-skill before responding.
Finance Acts (amendments to CITA before NTA 2025)
Regulations
Administrative Guidance
ng-income-tax).This skill and its outputs are for informational and computational purposes only and do not constitute tax, legal, or financial advice. All outputs must be reviewed and signed off by a Nigerian chartered tax practitioner (ICAN / ANAN / CITN) before filing or acting upon. NTA 2025 figures and mechanics labelled "TBC" must be verified against FIRS implementing regulations once published. The latest verified version of this skill is maintained at openaccountants.com.
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Review status
Accountant-reviewed
Reviewed by a named licensed practitioner against the stated sources, as general reference material.
Accountant-reviewed
Reviewed by Omolola Fasasi · 21 June 2026
A named accountant reviewed this complete Guide version within the stated scope. It is not a guarantee.
View review record →Other Nigeria computations in the OpenAccountants Tax Library.
Quick reference field table
| Field | Value | |---|---| | Country | Federal Republic of Nigeria | | Tax | Companies Income Tax (CIT) | | Currency | NGN (Naira) — ₦ | | Tax year | Accounting year of the company (any 12-month period; first/final years may be shorter) | | Primary legislation (2025) | Companies Income Tax Act, Cap. C21 LFN 2004, as amended by Finance Acts 2019–2023 | | Primary legislation (2026+) | **Nigeria Tax Act 2025 (NTA 2025)** — signed by President Tinubu 26 June 2025; effective **1 January 2026** | | Tax authority | **FIRS** — Federal Inland Revenue Service | | Filing portal | **FIRS Tax Pro-Max** (taxpromax.firs.gov.ng) | | Annual return deadline | **6 months** after accounting year-end (Section 55 CITA / equivalent NTA 2025) | | Payment | With return, or in instalments up to filing deadline (FIRS approval) | | Bookkeeping retention | 6 years (Section 63 CITA); align with NTA 2025 implementing regulations | | Skill version | 1.0 | | Validated by | Verified by Omolola Fasasi (MB058950) on 2026-06-21 |
Legacy CITA 2025 rate table
| Company size | Definition | CIT rate | |---|---|---| | Small | Turnover ≤ ₦25M (CITA s.40 as amended Finance Act 2019) | **0%** | | Medium | ₦25M < Turnover ≤ ₦100M | **20%** | | Large | Turnover > ₦100M | **30%** | | Tertiary Education Tax (TET) | All companies except small | 3% of assessable profit (Tertiary Education Trust Fund Act) | | NITDA levy | Companies with turnover ≥ ₦100M in specified sectors | 1% of profit before tax | | NASENI levy | Companies with turnover ≥ ₦100M in specified sectors | 0.25% of profit before tax | | Police Trust Fund levy | All companies | 0.005% of net profit |
NTA 2025 rate table (from 1 January 2026)
| Company size | Definition (NTA 2025) | CIT rate | |---|---|---| | **Small** | Turnover ≤ **₦100M** AND fixed asset base ≤ **₦250M** | **0%** | | **Medium** | ₦100M < Turnover ≤ ₦1B | **20%** | | **Large** | Turnover > ₦1B | **30%** in 2026, transitioning to ~**25%** by 2029 via tax-credit mechanism per NTA 2025 transitional schedule | | **Development Levy** (unified) | All non-small companies | **2%** of assessable profit — replaces TET, NITDA, NASENI, and Police Trust Fund levies | | **Minimum Effective Tax Rate (MET)** | Multinational groups with consolidated revenue > **€750M** | **15%** floor (Pillar Two GloBE alignment) |
Conservative defaults table
| Ambiguity | Default | |---|---| | Accounting period spans 1 Jan 2026 (CITA-to-NTA transition) | Apportion on a daily basis; apply legacy rules to pre-2026 portion, NTA 2025 to post-2026 portion | | Company size band unknown | Large (30% + 2% Development Levy) | | Asset base unknown for NTA 2025 small-company test | Assume > ₦250M (small-company status denied) | | Pillar Two MET applicability unclear | Treat as in-scope if any group entity is in a jurisdiction with consolidated revenue > €750M | | Capital allowance claim unsupported | Disallow until asset-register evidence is produced | | Loss carry-forward year unknown | Verify per-year schedule; treat oldest losses as expired under legacy 4-year limit if pre-Finance Act 2019 | | Pioneer status / IDITR relief uncertified | Apply standard rate; flag pending Industrial Inspectorate certificate | | TIN status unknown | Halt — TIN is mandatory before filing |
R-NG-CIT-1
Upstream oil & gas. Petroleum operations under the Petroleum Industry Act 2021 (PIA) — Hydrocarbon Tax (HT) and Companies Income Tax on midstream/downstream operations — require specialist handling. Escalate.Petroleum Industry Act 2021
R-NG-CIT-2
Banks, insurance, and pension funds. Sector-specific rules (CBN prudential disallowances, NAICOM rules, PenCom rules). Out of scope.
R-NG-CIT-3
Free trade zones (NEPZA, OGFZA, Lekki FTZ, Calabar FTZ). Approved Enterprise status may carry CIT exemption with conditions. Out of scope; escalate to a zone-licensed advisor.
R-NG-CIT-4
Pioneer status / Industrial Development Income Tax Relief (IDITR). Applications and ongoing eligibility are handled by NIPC, not by this skill. Apply standard CIT until pioneer certificate is in hand.
R-NG-CIT-5
Transfer pricing controversy or APA. Disputes, MAP, or active TP audits are out of scope. Standard TP documentation under the Income Tax (Transfer Pricing) Regulations 2018 is mentioned but full computation is escalated.Income Tax (Transfer Pricing) Regulations 2018
R-NG-CIT-6
Non-resident companies and digital services tax / Significant Economic Presence. Non-residents with SEP under Companies Income Tax (Significant Economic Presence) Order 2020 are out of scope.Companies Income Tax (Significant Economic Presence) Order 2020
R-NG-CIT-7
Group / consolidated returns. Nigeria does not permit consolidated CIT returns; each company files separately. Group transfer-pricing implications are out of scope.
R-NG-CIT-8
Active FIRS audit / assessment dispute. Companies with active FIRS Notice of Refusal to Amend (NORA), Tax Appeal Tribunal proceedings, or unpaid assessment notices must be escalated. Penalty and interest computations under Section 32 FIRS Establishment Act 2007 should be done by a chartered tax practitioner.Section 32 FIRS Establishment Act 2007
R-NG-CIT-9
Cross-skill scope. Personal income tax → `ng-income-tax`. VAT → `ng-vat-return` / `nigeria-vat`. This skill is corporate income tax only.
Charge to CIT
CIT is charged on the profits of any company accruing in, derived from, brought into, or received in Nigeria in respect of: Trade or business; Rent or premiums from land or property; Dividends, interest, royalties, discounts, charges, annuities; Fees, dues, allowances for services rendered; Any other annual profits or gains. NTA 2025 retains the same broad charging language with modernised drafting and explicit inclusion of digital and cross-border services.CITA s.9 / NTA 2025
Legacy 2025 thresholds
Small: Turnover ≤ ₦25,000,000 → 0% CIT, exempt from TET. Medium: ₦25M < Turnover ≤ ₦100,000,000 → 20% CIT. Large: Turnover > ₦100,000,000 → 30% CIT.Finance Act 2019 / 2020 amendments to CITA
NTA 2025 thresholds (from 1 January 2026)
Small: Turnover ≤ ₦100,000,000 AND fixed assets ≤ ₦250,000,000 → 0% CIT, exempt from Development Levy. Medium: ₦100,000,000 < Turnover ≤ ₦1,000,000,000 → 20% CIT + 2% Development Levy. Large: Turnover > ₦1,000,000,000 → 30% CIT phasing to ~25% by 2029 + 2% Development Levy.NTA 2025
Dual small-company test
Important: under NTA 2025 the small-company test is dual (turnover AND asset base). Failing either limb forfeits 0% status. The threshold leap from ₦25M to ₦100M (turnover) and the new ₦250M asset cap is one of the headline reforms.NTA 2025
Phasing description
Per NTA 2025 transitional provisions, the effective large-company CIT rate is reduced from 30% to approximately 25% through a phased tax credit between accounting years 2026 and 2029.NTA 2025 transitional provisions
Large-company rate phasing table
| Accounting year | Headline rate | Tax-credit reduction | Effective rate (approx.) | |---|---|---|---| | 2026 | 30% | TBC | ~28-30% | | 2027 | 30% | TBC | ~27% | | 2028 | 30% | TBC | ~26% | | 2029 onward | 30% | TBC | ~25% |
Conservative default
Conservative default: until FIRS publishes the phasing schedule, compute at the headline rate stated for the year and label any reduction as "subject to NTA 2025 implementing regulations".
Development Levy consolidation
NTA 2025 consolidates four legacy levies — Tertiary Education Tax (TET, 3%), NITDA levy (1%), NASENI levy (0.25%), and Police Trust Fund levy (0.005%) — into a single 2% Development Levy on assessable profits of all non-small companies. The Levy is administered by FIRS and reported on the CIT return.NTA 2025
MET applicability
Multinational enterprise groups with consolidated annual revenue exceeding €750 million in at least two of the preceding four years are subject to the 15% Minimum Effective Tax Rate (MET) introduced by NTA 2025 in alignment with the OECD/G20 Inclusive Framework Pillar Two GloBE Rules.NTA 2025 / OECD Pillar Two GloBE Rules
Mechanism
Mechanism: if the effective tax rate of the group's Nigerian operations falls below 15% after all credits, deductions, and incentives, a top-up tax brings the ETR to 15%. Pioneer status, free-trade-zone exemptions, and other tax holidays may be effectively neutralised within the MET scope.
Conservative default
Conservative default: if any group entity has consolidated revenue > €750M, flag MET as in scope and request the group's Pillar Two computation.
CIT computation layers
Adjusted Profit = Accounting profit ± non-allowable / non-taxable items Assessable Profit = Adjusted Profit on preceding-year basis (current accounting period) Total Profit = Assessable Profit − Capital Allowances − Loss Relief Tax Payable = Applicable CIT rate × Total Profit + Development Levy (2% × Assessable Profit, if not small) + MET top-up (if applicable) − WHT credits − Other allowable creditsCITA s.13 / NTA 2025 equivalents
WREN test and examples
Wholly, reasonably, exclusively, and necessarily (WREN) incurred in producing the profits. Examples: Interest on money borrowed and employed as capital (subject to thin-capitalisation: 30% EBITDA limit under Finance Act 2019, retained under NTA 2025); Rent of premises occupied for business; Repairs of premises, plant, machinery (not improvements); Bad and doubtful debts (subject to specific provisioning rules); Pension and gratuity contributions to approved schemes; Salaries, wages, allowances (subject to PAYE compliance); Donations to approved bodies (Fifth Schedule CITA; mirrored in NTA 2025); Research and development (with possible enhanced deduction under NTA 2025 — TBC); Bank charges, audit fees, professional fees.CITA s.24 / NTA 2025
Disallowed items
Capital expenditure (deduct via capital allowances, not as expenses); Domestic or private expenses; Sum recoverable under any insurance or contract of indemnity; Income tax itself, or any tax measured on profits; Penalties or fines for breach of law; Depreciation per accounts (replaced by capital allowances); Provisions for general reserves; Donations not on the Fifth Schedule; Expenses related to exempt income; Excess interest beyond the 30% EBITDA thin-cap limit (Section 13A of the Finance Act 2019 amendments / NTA 2025 equivalent).CITA s.27 / NTA 2025
Capital allowance rates per asset class
| Asset class | Initial allowance | Annual allowance | |---|---|---| | Building (industrial) | 15% | 10% | | Building (non-industrial) | 15% | 10% | | Furniture and fittings | 25% | 20% | | Motor vehicle | 50% | 25% | | Plant and machinery — agricultural | 95% | nil (effectively 100% Year 1) | | Plant and machinery — industrial | 50% | 25% | | Plant and machinery — other | 50% | 25% | | Computers (hardware) | 50% | 25% | | Software | 50% | 25% | | Research & development | 95% | nil (full Year 1 for approved R&D) |Second Schedule CITA / Sixth Schedule NTA 2025
Loss carry-forward rules
Legacy CITA: trade losses carried forward up to 4 years (extended to indefinite for non-insurance companies by Finance Act 2019). Insurance companies: 4-year cap (legacy). NTA 2025: indefinite carry-forward for all companies, subject to anti-abuse rules (no carry-forward where ≥ 50% ownership change combined with major change in trade — TBC under final regulations). No carry-back available.CITA / Finance Act 2019 / NTA 2025
Minimum tax rule
When a company has no total profit or total profit below the minimum-tax threshold, CITA s.33 (as amended by Finance Act 2019/2020) imposes a minimum tax of 0.5% of gross turnover less franked investment income. Exemptions: small companies, companies in the first 4 calendar years of business, and companies engaged in agricultural trade. NTA 2025: the minimum-tax regime is restructured.CITA s.33 as amended by Finance Act 2019/2020
WHT credit and franked investment income
WHT suffered on income (interest, dividends, rent, royalties, fees) is creditable against CIT liability, subject to WHT credit notes from the deducting party. Excess WHT can be refunded or carried forward. WHT on dividends paid out of profits already taxed at CIT — franked investment income — is not subject to further CIT (avoiding double taxation).
Pioneer status relief
Granted by the Nigerian Investment Promotion Commission (NIPC) under the Industrial Development (Income Tax Relief) Act. 5 years of tax holiday (3 + possible 2-year extension) for approved pioneer products and services. Conservative default: apply standard CIT until the Pioneer Certificate is in hand. Note that under NTA 2025 Pillar Two MET, pioneer-status relief may be neutralised for large multinationals.Industrial Development (Income Tax Relief) Act
Export CIT exemption
Companies engaged in 100% export of manufactured goods may qualify for CIT exemption under the Nigerian Export Promotion Council (NEPC) regime. Free Zone Enterprises under NEPZA are out of scope (see refusal R-NG-CIT-3).
REIC exemption
REICs registered with SEC enjoy CIT exemption on rental income distributed to unit holders, subject to NTA 2025 conditions. Refer to specialist for full REIC computation.NTA 2025
One-off investment allowance
An additional 10% one-off investment allowance on plant and equipment in addition to normal capital allowances under Section 32 CITA (legacy).Section 32 CITA
Interest deductibility limit
Finance Act 2019 introduced an interest-deductibility limit of 30% of EBITDA on related-party interest. Excess interest carries forward up to 5 years. NTA 2025 retains the rule with confirmation expected in implementing regulations.Finance Act 2019
TP obligations
Companies with related-party transactions must apply the arm's-length principle and file: TP declaration (annual, with CIT return); Master File / Local File (where thresholds met); CbCR (consolidated revenue > €750M). Full TP computation and controversy is out of scope (R-NG-CIT-5).Income Tax (Transfer Pricing) Regulations 2018
Donation deduction cap
Only donations to organisations listed in the Fifth Schedule CITA / NTA 2025 equivalent are deductible. Cap: 10% of Total Profit before donation.Fifth Schedule CITA / NTA 2025
Foreign tax credit relief
Companies taxed on foreign-source income may claim relief by Tax Treaty (where Nigeria has one — currently with UK, France, Belgium, Netherlands, Canada, Pakistan, Romania, China, South Africa, etc.) or unilateral relief under CITA s.45. Credit limited to the Nigerian CIT attributable to that income.CITA s.45
Form CIT components table
| Component | Content | |---|---| | CIT computation | Adjusted profit → Assessable profit → Total profit → Tax payable | | Capital allowance schedule | Per asset class, qualifying capital expenditure, allowances, TWDV | | Loss memo | Year of loss, amount, utilisation, balance c/f | | TET / Development Levy computation | Per applicable regime | | WHT credit schedule | WHT certificates, deducting party, amount | | Transfer pricing declaration | If applicable | | Audited financial statements | Signed by ICAN-licensed auditor | | Schedule of donations | Recipient, amount, Fifth Schedule reference |
Filing deadlines table
| Item | Deadline | |---|---| | **Annual CIT return** | Within **6 months** after end of accounting year (Section 55(2) CITA / NTA 2025) | | **Self-assessment payment** | With return; or by instalments approved by FIRS, last instalment by filing deadline | | **Provisional / advance returns** | Companies on PAYE-style advance payments: see FIRS taxpayer category rules | | **Pillar Two GloBE Information Return** | TBC under NTA 2025 implementing regulations (likely 15 months after FY-end, OECD-aligned) | | **TP returns** (declaration, disclosure) | With CIT return | | **CbCR** | 12 months after end of reporting accounting year |
CIT vs PAYE distinction
**Important distinction from personal income tax.** Monthly PAYE handling for employees is a separate monthly obligation under the Personal Income Tax Act (PITA) and is covered in `ng-income-tax`. Companies are PAYE agents — they withhold and remit monthly by the 10th of the following month. This is administrative withholding, not CIT.Personal Income Tax Act (PITA)
Penalties and interest table
| Infraction | Sanction | |---|---| | Late filing of CIT return | ₦25,000 in first month + ₦5,000 each subsequent month (CITA / Finance Act updates) | | Late payment | **10% penalty** + interest at CBN MPR + 5% per annum (Section 32 FIRS Establishment Act 2007) | | Failure to deduct / remit WHT | 10% of WHT due + interest | | Incorrect return | Up to 100% of tax shortfall plus interest | | Tax evasion / fraud | Fine up to ₦20,000 or 3× tax sought to be evaded, plus imprisonment up to 3 years |
TCC requirement
A TCC is required for many official transactions (government contracts, loan applications, immigration matters). FIRS issues TCC after CIT compliance verification. Companies in the first 4 years may be issued a "new business" TCC.
Statute of limitations
Standard period: 6 years from end of accounting year for FIRS to raise assessments (CITA s.66); no limit for fraud or wilful default.CITA s.66
Conservative defaults summary table
| Item | Default | |---|---| | Company size band unknown | Large (30% + 2% Development Levy or legacy levies) | | Asset base unknown (NTA 2025) | > ₦250M (small status denied) | | Accounting period straddles 1 Jan 2026 | Daily-apportion between CITA and NTA 2025 | | Pillar Two MET applicability uncertain | Treat as in scope if any group entity is in a group with revenue > €750M | | Pioneer status uncertified | Apply standard rate | | Capital allowance evidence missing | Disallow until asset register provided | | Loss carry-forward year uncertain | Schedule per-year; expire pre-2019 losses at 4 years if pre-Finance Act 2019 | | Donation recipient not in Fifth Schedule | Disallow | | Expense WREN test unclear | Disallow | | WHT credit certificate missing | Disallow until certificate produced | | Filing portal access uncertain | Confirm Tax Pro-Max enrolment before promising file dates | | NTA 2025 figure not yet published | Label "TBC — verify under NTA 2025 final implementing regulations" |
Cross-references table
| Topic | Skill | |---|---| | Personal income tax / PAYE | `ng-income-tax` | | VAT / value-added tax | `ng-vat-return` and `nigeria-vat` | | Foundation principles | `foundation` | | Intake checklist | `intake` | | References / sources index | `references` |
Rendered from the canonical facts model · facts last reviewed Jun 21, 2026. General reference only — confirm with a qualified professional before acting.
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