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Nigeria: Regulations implementing CRS regime

Nigeria: Regulations implementing CRS regime

The Federal Inland Revenue Service (FIRS) issued the Income Tax (Common Reporting Standard (CRS)) Regulations, 2019. The effective date of the regulations is 1 July 2019.


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The Federal Inland Revenue Service (FIRS) issued the Income Tax (Common Reporting Standard (CRS)) Regulations, 2019. The effective date of the regulations is 1 July 2019.

The regulations implement the following instruments:

  • Multilateral Convention on Mutual Administrative Assistance in Tax Matters and the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (AEOI) signed by Nigeria in August 2017
  • CRS regime and its commentaries contained in the Standard for AEOI in Tax Matters, approved by the Organisation for Economic Cooperation and Development and set out in the AEOI Implementation and Compliance Guidelines

The scope of the regulations concerns:

  • Matters under the CRS regime in Nigeria with respect to financial institutions’ implementation and compliance with the guidelines
  • Requirements regarding the due diligence procedures with respect to financial accounts and the reporting of financial account information to the FIRS that financial institutions will comply with when implementing and applying the guidelines
  • Requirements with respect to the effective implementation of the CRS regime in Nigeria

The regulations require a “reporting financial institution” for the 2019 calendar year and every subsequent calendar year, to file an “information return” with the FIRS setting out the information required to be reported about every “reportable account” that is maintained by the financial institution at any time during the calendar year.  When a reporting financial institution has identified it has no reportable accounts, the regulations require that the financial institution file an information return with the FIRS stating that it maintained no reportable accounts for that year. The deadline for submission of the information return under the regulations is 31 May of the year following the calendar year to which the return relates.

Read a September 2019 report [PDF 171 KB] prepared by the KPMG member firm in Nigeria

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