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HMRC internal manual

Double Taxation Relief Manual

Nigeria: Dividends

The agreement provides for Nigeria to be able to tax dividends at a rate of not more than 12½ per cent in respect of direct holdings and 15 per cent in respect of portfolio investments .However, the current domestic withholding rate in Nigeria is 10 per cent, with some dividends being exempt from withholding tax.

Underlying relief (INTM164060) is available under the agreement on dividends paid to companies which control, directly or indirectly, 10 per cent or more of the voting power in the company paying the dividend (Article 22 (1) (b)) .