Feature/OPED
Hidden Extra Tax ‘Tie’ for Parents Visiting Children Studying in the UK
By Julie Howard and Annabella King
There is a significant overhaul in UK tax legislation coming into effect come April of this year and going forwards exposure to UK tax will focus more closely on the length of an individual’s UK residence status. HNW Nigerians whose children are studying in the UK may not be aware that they could be UK resident on the basis of fewer days spent in the UK than expected. This will be dependent on their connections to the UK, including the time their children spend in the UK during school holidays and how much the parents see their children in the UK. It is vital that HNW Nigerians with connections to the UK clue up on this to avoid being caught out.
The new rules and UK residence
From 6 April 2025, the current “non-dom” regime will be replaced with a new residence-based regime.The concept of domicile will be abolished as a connecting factor for UK tax purposes and the remittance basis of taxation will be abolished from 6 April 2025.
Individuals moving to the UK from Africa, who have not been UK resident in any of the previous 10 years, will be eligible to claim a new favourable regime for those first 4 years whereby they will not pay UK tax on foreign income and foreign chargeable gains (known as FIG) even if these are brought into the UK. For individuals who have been UK tax resident for fewer than 4 tax years from 6 April 2025, they will be able to claim this favourable regime for the balance of their first 4 years of UK residence– assuming they meet the requirement of non-residence in the 10 years before they moved to the UK. The UK tax year runs from 6 April to the following 5 April.
For UK tax purposes, liability to inheritance tax has historically been based on the concept of domicile, which is essentially where someone regards their permanent home. From 6 April 2025, domicile will cease to be a connecting factor for inheritance tax purposes. Instead, it will be based on UK residence with an individual becoming subject to inheritance tax on their worldwide estate once they have been UK tax resident for 10 of the previous 20 tax years, known as a “long term resident”.
Whether or not an individual is UK resident will therefore be extremely important under the new rules.The UK has a statutory residence test (the SRT) to determine an individual’s residence status for UK tax purposes. The SRT breaks down into three tests which must be considered in order: firstly, the automatic non-residence test; secondly, the automatic UK residence test; and finallythe sufficient ties test. Whilst the SRT sets out a clear test to determine an individual’s residence, there are still some areas of uncertainty. For example, many of the definitions used, such as “work” and “home” are specific to the legislation and not straightforward and there are specific pitfalls to be aware of such as the hidden extra “tie” for parents visiting children who are studying in the UK.
Hidden extra tax “tie”
For individuals who are not automatically UK resident or automatically non-UK resident under the automatic tests of the SRT, whether they are UK resident will depend on the number of “ties” (i.e. links) that they have with the UK. There are five different ties:
- Family tie – your spouse/civil partner or common law equivalent or minor child/children are UK resident
- Work tie – you work in the UK for at least 40 days (and this applies if you work for more than three hours a day)
- Accommodation tie – you have a place to live in the UK (i.e. a home, a holiday home or accommodation otherwise available to you) which is available for a continuous period of at least 91 days in the tax year and you spend at least one night there in that year. This can include accommodation owned by relatives if certain conditions are met and also rental properties
- 90 day tie – you spent more than 90 days in the UK in either of the previous two tax years
- Country tie – you spent more days in the UK in that tax year than in any other single country (this tie only applies to “leavers” – i.e. individuals who are ceasing UK residence).
African parents with minor children studying in the UK may have a “family tie” on top of other ties and this will reduce the number of days that they are able to spend in the UK without becoming UK resident under the SRT.
Parents witha child under the age of 18 who is in full-time education in the UK should be aware that they may acquire a “family tie” by reason of their childbeing educated in the UK. This will occur iftheir child spends 21 days or more in the UK outside of term time, for example, during the main Christmas, Easter and Summer holidays (the half-term breaks are regarded as term-time); and they see their children on 61 days or more in the UK during the tax year.
If, for example, a child was to spend a week in the UK before term started in September and two weeks in the UK during the Christmas holidays (rather than returning to Africa or going on holiday somewhere outside the UK), this 21 day limit could easily be exceeded and then it would be important for the parent to keep below the 61 day limit to avoid a family tie.
If the parent did acquire a family tie as a result of the above limits being exceeded, they could end up being UK tax resident on the basis of a lower number of days spent in the UK than expected if, for example, they also have available accommodation in the UK and work for more than 3 hours a day on 40 days or more during the tax year– giving a total of 3 ties.
Nigerian parents with children studying in the UK should take advice on their UK residence position if they are unsure as to how much time they can spend in the UK without becoming UK resident.
Julie Howard is a Private Client and Tax Partner at Boodle Hatfield and Annabella King is an Associate
Feature/OPED
What Does Nigeria’s $51bn Reserves Milestone Mean if Most New Foreign Money Can Leave Quickly?
Nigeria’s foreign reserves have climbed to about $51 billion, a decade-plus high, according to the Central Bank of Nigeria (CBN). EBC Financial Group (EBC) notes that this reflects stronger investor confidence, but the second half may show whether it holds, as the build rests on three cyclical drivers: oil earnings, short-term foreign money and a narrowing official-to-street naira gap.
Reserves rose from about $32 billion in April 2024, during a dollar shortage, to about $51 billion now, near the CBN’s target. Much came from two cyclical sources, strong oil earnings and money chasing high-yielding naira assets, so EBC expects the pace to slow or reverse. Fitch Ratings, a major international credit rating agency, expects a marginal decline to about $47 billion by the end of 2026, citing higher spending and external pressures.
David Precious, Senior Market Analyst at EBC Financial Group, said, “Nigeria’s reserve build is real but may not be durable yet, because nearly all of the new money is the kind that can leave quickly. Of the $10.37 billion that came in over the first quarter, the overwhelming majority was short-term portfolio funds rather than long-term investment, so a shift in oil prices, global interest rates or confidence in the naira might pull a large part of it straight back out.”
Most New Money Can Still Leave Quickly
The composition of the foreign inflows explains the caution over how long the build can last. The country attracted $10.37 billion in foreign investment in the first quarter of 2026, up 83.83 per cent year-on-year, according to the National Bureau of Statistics (NBS). Of that, $9.86 billion or 95.09 per cent, was portfolio money, largely short-term naira debt such as Treasury bills that investors can sell at the next auction, while foreign direct investment, the long-term kind that builds factories and jobs, was $135.08 million, or 1.30 per cent. Put simply, of each dollar coming in, about 95 cents can leave quickly, and barely one cent stays.
That money supports reserves while it stays. Dollars brought in to buy naira assets add to market supply, letting the CBN hold more reserves and steady the naira. It leaves when conditions change. Nigeria earns most of its export dollars from oil and gas, so lower oil prices mean fewer dollars, and as a member of the Organisation of the Petroleum Exporting Countries (OPEC), it cannot simply produce more, output capped by quota and reduced by theft and ageing fields. Higher global interest rates draw money toward safer returns abroad, and a weakening naira prompts investors to sell early. When oil fell in 2016 and 2020, foreign investors withdrew and could not convert naira to dollars as supply dried up, leaving the CBN to clear more than $7 billion in trapped obligations into 2024.
The Oil Boost is No Longer Certain
Oil looked like a dependable source of the dollars behind the reserves only months ago. Earlier in 2026, concern over disruption around the Strait of Hormuz lifted crude prices, and stronger receipts flowed in, with crude oil export earnings of $8.11 billion in the first quarter in the CBN’s balance-of-payments data. That support is now easing. The tension has subsided, and Brent traded near $72 on June 29, down about 24 per cent over the month, back to pre-conflict levels. With the price boost gone and output constrained, reserves are more exposed, leaning on non-oil earnings and investor patience rather than oil.
The Naira Still Trades at Two Prices
The naira has traded at two prices, an official rate and a higher parallel-market rate, and closing that gap into one trusted price is what many investors might watch most. Before committing funds, they may want assurance they can convert naira to dollars at a fair rate when they exit, and a wide gap revives the fear of being trapped that lingers from earlier shortages. The gap has narrowed to roughly N20 to N30, with the CBN’s official rate near N1,380 per dollar on June 26 against parallel-market quotes around N1,400. The International Monetary Fund (IMF) 2026 Article IV review urged Nigeria to depend less on this fast-moving portfolio money and to keep phasing out its multiple exchange-rate practices. The CBN’s Foreign Exchange Manual, in force from 1 June, is intended to make the market clearer, though such rules build confidence only once investors can freely trade dollars at the posted rate.
What could Make the Build Durable
A few signs that may show the build turning durable include a smaller gap between the official and street naira rates, more long-term foreign investment, and steadier oil earnings. A gap that stays small, now roughly N20 to N30, may mean investors trust the official rate and no longer need the street market. A clear rise in foreign direct investment, only $135 million last quarter against $9.86 billion of short-term money, might mean lasting capital is replacing funds that can leave at the next auction. Oil earnings that hold up, rather than sliding from the low $70s, should help keep reserves steady, since oil and gas bring in most of Nigeria’s export dollars.
“Reserves built on money chasing high yields can fall as fast as they rose, as they did after the last two oil shocks, when investors left, and the CBN spent years clearing a foreign-exchange backlog,” Precious added. “What holds through a downturn is slower money, direct investment, steady oil and non-oil export earnings and one credible naira rate, and that is the shift Nigeria has yet to make.”
By Olajumoke Bello
Across Nigeria, small and medium enterprises remain the backbone of economic activity. They drive trade, create jobs, and sustain millions of livelihoods. Yet, despite their importance, many SMEs continue to operate below their full potential due to persistent structural challenges.
Access to finance remains one of the most cited constraints. However, the issue today goes beyond the availability of capital. Many businesses struggle with financial readiness, weak documentation, and limited understanding of what lenders require. This often leads to missed opportunities, even when funding options exist.
At the same time, SMEs face gaps in market access and visibility. Business owners operate in highly localised environments, with limited exposure to broader networks that can unlock partnerships, new markets, and growth opportunities. This isolation can constrain scalability and reduce long-term competitiveness.
Equally important is the capability gap. Many entrepreneurs grow through resilience and experience but lack structured knowledge on critical areas such as financial management, export readiness, and digital adoption. Without this, even well-capitalised businesses can struggle to sustain growth.
These challenges point to a clear need for a more practical and integrated approach to SME support. It is no longer sufficient to offer standalone solutions. SMEs require ecosystems that combine knowledge, access, and direct engagement in ways that reflect how they actually operate.
A key shift is the move from centralised interventions to localised engagement. SMEs are deeply influenced by their immediate environments, whether markets, industrial clusters, or trade corridors. Solutions must therefore be brought closer to where these businesses function, allowing for more relevant support and stronger relationships.
Another important shift is from awareness to action. Business owners do not only need information; they need insights that they can apply immediately. This includes understanding how to structure their finances, how to access trade opportunities, and how to connect with the right partners to scale their operations.
There is also a growing need for continuity. Many SME-focused initiatives deliver strong initial impact but lack follow-through. For support to be effective, it must extend beyond one-off engagements into sustained relationships, with clear pathways for onboarding, advisory, and growth.
For financial institutions, this presents both responsibility and an opportunity. Supporting SMEs now requires moving beyond transactional banking to deeper partnership models. It requires understanding businesses at a granular level and co-creating solutions that evolve with their needs.
At Stanbic IBTC, this perspective continues to shape our approach to SME development. Our focus is on delivering practical support that translates into real business outcomes, helping enterprises grow, compete, and contribute more meaningfully to the economy.
As part of this commitment, we are extending our SME engagement to the regions through the Nigeria Business Summit Regional Tour. The tour will take structured, on-ground activations into key commercial hubs, where SMEs can access funding guidance, trade insights, advisory support, and direct engagement with financial experts.
The regional tour will take place across five strategic locations, bringing these solutions closer to business owners in Aba, Onitsha, Ibadan and Kano.
This approach reflects an important principle. When support moves closer to businesses and when solutions are delivered in ways that are practical and continuous, SMEs are better positioned to grow sustainably. In turn, this strengthens not only individual enterprises but the broader economy.
Olajumoke Bello is the Head of Enterprise Banking at Stanbic IBTC Bank
By Winston Osuchukwu
The average Nigerian borrower is widely considered high-risk – a claim repeated in credit committees, priced into retail loans, and largely treated as settled fact. Every credit market accepts that an individual loan may not be repaid; this is ordinary, priced risk. The high-risk claim, however, is applied to whole segments – the informal trader, the gig economy earner whose income is steady but split across several accounts, the remote worker paid by an overseas client into a fintech FX wallet. What the assessment establishes is not whether they are likely to repay, but how they fit into an arbitrary segment. Having spent years building decisioning systems for this market, my thesis is a specific one: “high-risk” does not mean “no credit” – it simply requires that the lender embrace alternative datasets to price the risk appropriately.
This is not a criticism of the institutions that built their frameworks around collateral and documentation; those were rational responses to the tools available at the time. When data is scarce, prudence means defaulting to the status quo. The limitation is not that this approach is wrong, but that it leaves a blind spot – excluding fundamentally sound borrowers whose economic lives simply are not captured on the bank’s ledger. A market trader who has moved consistent, growing volumes of cash through mobile money for three years is not, in any meaningful sense, unknowable. Their financial behaviour is observable and patterned; it simply occurs outside the traditional banking system, rendering it invisible to conventional underwriting.
This is the gap technology is now positioned to close – not by replacing institutional judgment, but by augmenting it. When AI-driven analysis is applied rigorously to the financial behaviour these borrowers generate, a far more complete picture of their repayment ability emerges – and a meaningful share presents a risk profile that compares favourably with segments the traditional system has long considered safe. The “high-risk” label, applied broadly to an entire category of borrower, was never a risk pricing tool so much as the limit of what the available tools could see.
For banks, this is the opportunity to extend capital with confidence beyond the borrowers who fit their stringent criteria. Nigerian banks are highly liquid; the constraint on credit growth has rarely been capital, but the ability to assess and price the borrowers who sit outside the traditional file. Close that gap, and the whole ecosystem strengthens: banks grow their loan books into segments they have long wanted to serve, and the real economy gets the capital it needs to expand.
This is precisely what we focus on at Mathesis Analytics: building AI-powered credit decisioning that gives lenders a fuller, more defensible picture of the individuals long excluded as high-risk when they were simply misjudged. The Nigerian credit gap has never been a non-lendable population problem, but one of incomplete visibility. By unifying varied data sources and partnering with the institutions that hold the capital and scale to move the market, we translate out-of-ecosystem behaviour into reliable, bank-grade risk scores. Closing this gap is one of the clearest, highest-leverage opportunities in Nigerian financial services today.
Winston Osuchukwu is the founder & CEO of Mathesis Analytics
