Economy
What Nigeria’s Signing of OECD’s Multilateral Instrument Means for Taxpayers
By Seun Adu and Olanrewaju Alabi
Consider this puzzle. It takes 5 machines 5 minutes to manufacture 5 widgets. How many minutes will it take 100 machines to manufacture 100 widgets? If you answered this in a hurry, you probably said 100. This is wrong. The correct answer is 5. But what does this have to do with the Multilateral Instrument (MLI)? I will come back to this in a bit.
When the international community agreed there was a need to fix the international tax rules through the BEPS project, one of the problems they had to address was how to ensure that the recommendations from the project could be quickly implemented by everyone that was involved.
Implementing the BEPS recommendations would require countries to make several changes to (a) their local tax legislation; and (b) the avoidance of double taxation agreements (DTA) that they had with other countries. Making changes to DTAs was clearly the more challenging issue because of the time and resources required to do so.
Participants in the BEPS project realized that if the old way of updating DTAs was used to implement the BEPS actions, it would take many years before the BEPS recommendations would become fully effective in most countries. This would defeat the purpose of the project.
The Multilateral Instrument (MLI) was developed to deal with this challenge.
What is the MLI?
In its full form, it is called the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Multilateral Instrument or MLI). The MLI is a single agreement between many countries. It allows a country to make concurrent changes to all or some of the DTAs that it has with other countries.
Quick overview of DTAs
Countries that do a lot of trade with one another usually sign agreements for the avoidance of double taxation to ensure that tax, in particular double taxation, does not become an obstacle to their trade activities. DTAs help to reduce the incidence of double taxation in several ways including: specifying which country has a right to tax a certain type of income, providing for reduced taxes on certain categories of income, etc.
DTAs usually follow a standard template or model. The two most used models are the OECD and UN models developed by the OECD and UN respectively. These models were first developed in the 1920s and are updated from time-to-time to deal with new tax issues.
Whenever a model is updated to address a particular tax issue, countries that follow the model try to make the changes to each of their DTAs to ensure that they can also address the issue.
Updating DTAs is not easy
The process of negotiating DTAs and ratifying them into law is usually long and difficult. Even after an agreement has been reached, it can still take many years before it takes full effect. For instance, the DTA between Nigeria and South Africa only came into force in 2008 even though the original agreement was signed in April 2000.
Negotiations for updating DTAs would typically not take as long as the negotiations for new agreements, but they still take a lot of time and resources. As a result of this, many countries do not update their DTAs as often as they should. This means that many DTAs are outdated.
For the BEPS project to be successful it was necessary to overcome this challenge since implementing the recommendations would require each country to update all of its DTAs. If countries followed the old way of having one-on-one negotiations with their existing treaty partners it would take many years for all the negotiations to be concluded and many more years for the agreements to be ratified by each country.
Such a delay would defeat the whole purpose of the BEPS project.
How the MLI solves the problem
The MLI removes the need for treaty partners to renegotiate the terms of existing DTAs one after the other making it possible to update the provisions of several double tax treaties with the relevant BEPS updates at the same time. It also makes it possible to pursue the domestication of the changes to all the treaties at once.
This is possible because the changes to be adopted through the MLI were based on collective negotiations between the countries that developed the instrument.
Some of the treaty changes are compulsory (these are the minimum standards) for all parties to the MLI while others are optional. Both the compulsory and optional changes have been standardized. The good thing about this is that the areas that will require one-on-one negotiations are not so many and these negotiations will be limited to choosing between several standardized options.
The process requires each country to submit an MLI position to the OECD. The MLI position is a document that contains details of the changes (based on the provisions of the MLI) that a particular country would like to make to each of its DTAs. This is then compared to the MLI positions of its other treaty partners.
Where the MLI positions of the parties to a particular treaty are the same, it means that an agreement has been reached on the specific provisions that match. The parties can then engage each other to discuss and agree on any positions that are different.
The effect is that a country can potentially renegotiate and ratify many of its tax treaties in almost the same time that it would normally have taken to re-negotiate one agreement. If I go back to my earlier puzzle for a second, the reason it takes only 5 minutes for the 100 machines to manufacture the 100 widgets is because they work simultaneously. This is pretty much how the MLI works.
What has Nigeria done so far?
Nigeria signed the MLI on 17 August 2017. Nigeria has also submitted its MLI position. This means that it is already possible to tell the changes that Nigeria plans to make to all of its existing double tax treaties.
In its MLI position, Nigeria listed DTAs with 19 treaty partners for amendment. These include the agreements that are already in force and those that are not yet in force (e.g. DTAs with Korea, Mauritius, United Arab Emirates etc.)
Also, of the 19 agreements, 13 treaty partners (including Belgium, Canada, China, Netherlands, and the United Kingdom) have all listed their DTAs with Nigeria for amendment under the MLI. This means that one can already check what treaty positions match and tell the changes that will likely be made to these DTAs.
The next steps will be for Nigeria and its treaty partners to agree on any parts of their proposals that do not match. Subsequent to this, each partner will then need to undertake the local domestication process to ensure that the changes become law. All of this could happen a lot quicker than we are used to.
Final thoughts
These are some of the changes that taxpayers need to be aware of due to the potential implications for their tax affairs. One of the changes is the introduction of the Principal Purpose Test (PPT) for tackling treaty shopping. Another important one is the amendments to the definition of Permanent Establishments in the treaties.
Nigerian resident taxpayers who currently enjoy treaty benefits should consider how the MLI will affect them. In addition, companies who plan to set up new structures that will allow them get treaty benefits will need to be mindful that the MLI could reduce the effectiveness of those structures.
Although the MLI position submitted by Nigeria on August 17 is provisional and subject to change, there is already a lot that one can deduce about how taxpayers will be impacted when the proposals finally become law.
Seun Adu is an Associate Director and Transfer Pricing Leader at PwC Nigeria. He is a regular writer and public speaker on tax and transfer pricing matters.
Olanrewaju Alabi is a Senior Associate with PwC Nigeria’s Transfer Pricing practice.
By Adedapo Adesanya
Nigeria and the United Kingdom are moving to tackle a long-standing £1.2 billion discrepancy in their trade records, with both countries agreeing to develop a structured data-sharing system aimed at improving transparency and accountability across bilateral commerce.
The agreement was reached during a high-level meeting in London on March 18, 2026, held on the sidelines of President Bola Tinubu’s State Visit, under the Nigeria–United Kingdom Enhanced Trade and Investment Partnership (ETIP).
According to a statement by Nigeria Customs Service (NCS) spokesperson, Mr Abdullahi Maiwada, the talks signal a shift toward deeper operational cooperation between both countries’ customs authorities.
At the centre of the discussions was a persistent mismatch in trade figures. While Nigeria recorded about £504 million worth of imports from the UK in 2024, British records show exports to Nigeria at approximately £1.7 billion for the same period, leaving a gap of roughly £1.2 billion.
To address this, the two countries agreed to explore a pre-arrival data exchange framework that will connect their digital customs systems, with the aim of improving risk management, reconciling trade data, and strengthening compliance monitoring along the corridor.
The meeting was led by Comptroller-General of Customs, Mr Adewale Adeniyi and Ms Megan Shaw, Head of International Customs and Border Engagement at His Majesty’s Revenue and Customs (HMRC), and also focused on customs modernisation and data transparency.
Mr Adeniyi underscored the broader economic implications of the initiative, noting that customs collaboration plays a central role in trade facilitation.
“Effective customs cooperation remains a critical enabler of economic growth and sustainable trade development,” he said.
He added that “customs administrations serve as the frontline institutions responsible for ensuring that trade flows between both countries are transparent, secure, and mutually beneficial.”
The Nigeria–UK trade relationship spans multiple sectors, including industrial goods, agriculture, energy, and consumer products — all of which depend heavily on efficient port and border operations.
Beyond addressing data gaps, the meeting also highlighted ongoing modernisation efforts on both sides. The UK showcased advancements in artificial intelligence-driven trade tools, digital verification systems, and real-time analytics designed to enhance cargo processing, risk assessment, and border security.
The engagement further produced plans for a Customs Mutual Administrative Assistance Framework, alongside technical groundwork for capacity building, knowledge exchange, and a joint engagement mechanism under the ETIP platform.
Mr Maiwada said the outcomes are expected to strengthen Nigeria’s trade ecosystem and support broader economic reforms.
“The NCS has reaffirmed its commitment to deepening international partnerships as part of a broader modernisation agenda designed to promote transparency, efficiency, and competitiveness in Nigeria’s trading environment,” the statement said.
It added that “insights from this engagement will strengthen its operational capacity, enhance trade facilitation, and support Nigeria’s economic reform objectives under the Renewed Hope programme.”
By Adedapo Adesanya
Dangote Petroleum Refinery imported a total of $3.74 billion) worth of crude oil in 2025, to make up for shortfalls that threatened the plant’s 650,000-barrel-a-day operational capacity.
The data disclosed in the Central Bank of Nigeria’s Balance of Payments report noted that “Crude oil imports of $3.74 billion by Dangote Refinery” contributed to movements in the country’s current account position, as Nigeria imported crude oil worth N5.734 trillion between January and December 2025.
Last year, as the Nigerian National Petroleum Company (NNPC), which is the refinery’s main trade partner and minority stakeholder, faced its challenges, the company had to forge alternative supply links. This led to the importation of crude from Brazil, Equatorial Guinea, Angola, Algeria, and the US, among others.
For instance, in March 2025, the company said it now counts Brazil and Equatorial Guinea among its global oil suppliers, receiving up to 1 million barrels of the medium-sweet grade Tupi crude at the refinery on March 26 from Brazil’s Petrobras.
Meanwhile, crude oil exports dropped from $36.85 billion in 2024 to $31.54 billion in 2025, representing a 14.41 per cent decline, further shaping the external balance.
The report added that the refinery’s operations also reduced Nigeria’s reliance on imported fuel, noting that “availability of refined petroleum products from Dangote Refinery also led to a substantial decline in fuel imports.”
Specifically, refined petroleum product imports fell sharply to $10.00 billion in 2025 from $14.06 billion in 2024, representing a 28.9 per cent decline, while total oil-related imports also eased.
However, this was offset by a rise in non-oil imports, which increased from $25.74 billion to $29.24 billion, up 13.6 per cent year-on-year, reflecting sustained demand for foreign goods.
At the same time, the goods account remained in surplus at $14.51 billion in 2025, rising from $13.17 billion in 2024, supported largely by activities linked to the Dangote refinery and improved export performance in other segments.
The CBN stated that the stronger goods balance was driven by “significant export of refined petroleum products worth $5.85bn by Dangote Refinery,” alongside increased gas exports to other economies.
Nigeria posted a current account surplus of $14.04 billion in 2025, lower than the $19.03 billion recorded in 2024 but significantly higher than $6.42 billion in 2023. The decline from 2024 was driven partly by structural changes in oil trade flows, including crude imports for domestic refining, according to the report.
Pressure on the current account came from higher external payments. Net outflows for services rose from $13.36 billion in 2024 to $14.58 billion in 2025, driven by increased spending on transport, travel, insurance, and other services.
Similarly, net outflows in the primary income account surged by 60.88 per cent to $9.09 billion, largely due to higher dividend and interest payments to foreign investors.
In contrast, secondary income inflows declined slightly from $24.88 billion in 2024 to $23.20 billion in 2025, as official development assistance and personal transfers weakened, although remittances remained a key source of inflow, as domestic refineries grappled with persistent feedstock shortages, exposing a deepening supply paradox in the country’s oil sector.
This comes despite the Federal Government’s much-publicised naira-for-crude policy designed to prioritise local supply.
By Aduragbemi Omiyale
An application has been submitted by Sovereign Trust Insurance Plc for its proposed N5.0 billion rights issue.
The application was sent to the Nigerian Exchange (NGX) Limited, and it is for approval to list shares from the exercise when issued to qualifying shareholders.
A notice signed by the Head of Issuer Regulation Department of the exchange, Mr Godstime Iwenekhai, disclosed that the request was filed on behalf of the underwriting firm by its stockbrokers, Cordros Securities Limited, Dynamic Portfolio Limited and Cedar of Lebanon Securities.
The company intends to raise about N5.022 billion from the rights issue to boost its capital base, as demanded by the National Insurance Commission (NAICOM) for insurers in the country.
Sovereign Trust Insurance plans to issue 2,510,848,144 ordinary shares of 50 Kobo each at N2.00 per share on the basis of three new ordinary shares for every 17 existing ordinary shares held as of the close of business on Tuesday, March 17, 2026.
“Trading license holders are hereby notified that Sovereign Trust Insurance has through its stockbrokers, Cordros Securities Limited, Dynamic Portfolio Limited and Cedar of Lebanon Securities, submitted an application to Nigerian Exchange Limited for the approval and listing of a rights issue of 2,510,848,144 ordinary shares of 50 Kobo each at N2.00 per share on the basis of three new ordinary shares for every 17 existing ordinary shares held as of the close of business on Tuesday, March 17, 2026,” the notification read.
-
Feature/OPED6 years agoDavos was Different this year
-
Travel/Tourism10 years ago
Lagos Seals Western Lodge Hotel In Ikorodu
-
Showbiz3 years agoEstranged Lover Releases Videos of Empress Njamah Bathing
-
Banking8 years agoSort Codes of GTBank Branches in Nigeria
-
Economy3 years agoSubsidy Removal: CNG at N130 Per Litre Cheaper Than Petrol—IPMAN
-
Banking3 years agoSort Codes of UBA Branches in Nigeria
-
Banking3 years agoFirst Bank Announces Planned Downtime
-
Sports3 years agoHighest Paid Nigerian Footballer – How Much Do Nigerian Footballers Earn