PwC Warns of Legal Gaps in Nigeria's Virtual Asset Tax Rules

PwC Nigeria has raised concerns regarding the legal uncertainties and enforcement challenges in the new tax framework for virtual assets, as outlined in its August 2026 tax alert titled ‘Taxing the intangible: A critical analysis of the NRS guidelines on taxation of virtual assets.’ The Nigeria Revenue Service (NRS) published Information Circular No. 2026/21 on July 31, 2026, marking Nigeria's first comprehensive administrative framework for taxing virtual assets. PwC noted that the guidelines lack an effective date and introduce new obligations not found in the Nigeria Tax Act or Nigeria Tax Administration Act.

The framework imposes various tax liabilities, including income tax on individuals and companies, a 1% withholding tax on gross disposal proceeds for cryptocurrencies, and a 7.5% VAT on taxable supplies related to virtual asset transactions. Additionally, a 1.5% stamp duty is required on token-to-fiat and fiat-to-token transfers.

PwC highlighted potential implications of the stamp-duty provision, suggesting that it could affect transfers of goods and intangible property.