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

By Jerome-Mario Utomi

For the good people of Delta and other adjoining states, Saturday, February 22, 2025, will remain an indelible date. The reason for this assertion is simple.  It was on that day that the Minister of Regional Development, Engr. Abubakar Momoh, has commissioned the 9.6- kilometre Abraka-Oben Road reconstructed by the Niger Delta Development Commission, NDDC, in Abraka, Ethiope East Local Government Area of Delta State. He also launched the reconstruction of the Abraka-Agbor Road.

Indeed, there are reasons why the people, particularly the road users, are happy with the latest feat achieved by the NDDC Governing Board and Management.

Aside from preventing accidents and loss of lives as a result of its formerly deplorable state, it is globally acknowledged that infrastructure enables development and also provides the services that underpin the ability of people to be economically productive, for example via transport. “The transport sector has a huge role in connecting populations to where the work is,”.

Also, Infrastructure investments help stem economic losses arising from problems such as traffic congestion. The World Bank estimates that in Sub-Saharan Africa closing the infrastructure quantity and quality gap relative to the world’s best performers could raise GDP growth per head by 2.6 per cent annually.

In addition to the highlighted importance of infrastructures to the nation’s economic development, a glance through the commentaries by dignitaries present at the commission further reveals that NDDC as a commission has done well.

Delta State Governor, Rt. Hon. Sheriff Oborevwori commended the Niger Delta Development Commission, NDDC for the initiative to reconstruct the all-important access road from Abraka to Oben, saying that Mr President picked very good people in managing different ministries, departments and agencies for the good of Nigerians.

Governor Oborevwori, who made remarks at the inauguration of the reconstructed road, also thanked Mr President for picking very good people in managing different ministries departments and agencies for the good of Nigerians, Delta State Governor reiterated the state government’s willingness to partner with the Federal Government for the overall socio-economic development of the state.

Represented by the State Commissioner for Works (Highways and Urban Roads), Comrade Reuben Izeze, Governor Oborevwori said his administration remained irrevocably committed in its partnership with the President Bola Tinubu-led federal government for the transformation of the state.

He said the Oborevwori governance philosophy believes that if the Federal Government succeeds, it would dovetail in the success of the subnational governments.

He commended the Niger Delta Development Commission, NDDC for the initiative to reconstruct the all-important access road from Abraka to Oben and called for the completion of the road to Benin.

“I thank the board of the NDDC for the vision and for acknowledging the challenges and for giving the policy guideline for the execution of this laudable project. I am glad that the NDDC is giving special attention to reconstruction of failed portions on roads across the region. The Government of Delta State believes very strongly and firmly that we are partners in progress with the Federal Government led by President Bola Tinubu.

“We believe in the success of the Federal Government because of the nature of our Constitution and its operations, the success of the Federal Government will naturally translate to the success of the states as well.  Governor Oborevwori therefore wishes to commend President Bola Tinubu for his support for the board of the NDDC thus far and urging him to continue to do more for the people of the Niger Delta,” he added. “I thank Mr President for picking very good people in managing different ministries, departments and agencies for the good of Nigerians,” he concluded.

Similarly, speaking at the inauguration ceremony, Engr. Momoh, said that the road projects were further demonstrations of the determination of the Federal Government to develop the Niger Delta region. The Minister commended the NDDC Board and Management for responding appropriately to the directives of President Bola Tinubu’s charge to turn things around in the Niger Delta region positively.

In his remarks, the Chairman of the NDDC Governing Board, Mr Chiedu Ebie, said that the project was a reflection of the President Tinubu administration’s desire to transform the Niger Delta Region into a zone of peace and development. He said, “Since we assumed office, this is the first landmark project being commissioned in Delta State. I commend the management team for continuously implementing the board’s policies and following President Bola Ahmed Tinubu’s directives.

“Today, we are commissioning the re-constructed Abraka-Oben Road and flag-off the reconstruction of the Abraka-Agbor Road. These are landmark projects, and I am happy with the work being done. As a Delta State indigene, I am proud that my people are well represented.”

For his part, the NDDC Managing Director, Dr Samuel Ogbuku, affirmed that the NDDC was dedicated to advancing the implementation of the President’s Renewed Hope Agenda. “We are determined to make the Renewed Hope Agenda of the Federal Government a reality in the Niger Delta region, and we remain committed to the mandate given to the Commission to change the narrative in Nigeria’s oil-producing region.

“Today, there is peace in the NDDC and the region. The youths and other stakeholders are happy with our efforts. That is the success we have toiled so hard to achieve for our people. We thank our stakeholders for their support and encouragement, which has boosted our desire to ensure that we give them what they deserve. We appreciate the state governments for supporting us and partnering with us in several areas of development. We believe that in partnership with stakeholders, we will achieve more, and development in our region will be faster and more holistic. We are not competing with any state government; we only complement their efforts.”

The NDDC Executive Director of Projects, Sir Victor Antai, gave the project brief and explained that the scope included the construction of a 9.6 km asphalt pavement with an 8m carriage width.

He noted: “The restoration of this critical infrastructure required replacing over 80,000m3 of unsuitable material and the dilapidated sections of the Araka-Oben Alignment. Before now, the road was not motorable and became a hot spot for kidnapping and armed robbery activities.

“This important interstate road project connects various industrial and agricultural communities in Delta and Edo States, facilitating the transportation of goods and services”

Also speaking at the ceremony, the Chairman of the House Committee on NDDC, Erhiatake Ibori-Suenu, congratulated the NDDC management for significantly impacting her Federal Constituency.

Speaking earlier during a courtesy visit by the NDDC team led by the Minister of Regional Development, the traditional ruler of Oruarivie-Abraka Kingdom, King Akpomeyoma Majoroh, commended the Commission for its commitment to regional development. He emphasised the strategic importance of the road project, stating: “As a serious agricultural area, most of our people are farmers. This road has facilitated the easy movement of people and agricultural produce, fostering thriving commercial activities. It is important to us, and we are very grateful for it’.’

The royal father noted that the road served as a regional link, connecting Abraka to Benin, and expressed gratitude for connecting the community to their ancestral home.

Utomi, a media specialist, writes from Lagos, Nigeria. He can be reached via [email protected] or 08032725374

Dubai-based cryptocurrency exchange Bybit was the victim of what is being widely reported as the single largest digital theft in history. Hackers extracted approximately $1.5bn (£1.2bn) from an Ethereum wallet and transferred the contents to a new, unlocatable address.

The platform has assured users of its liquidity—despite a significant increase in the volume of withdrawals in the wake of the breach—promising refunds to all affected users even if the stolen money is not recovered.

According to Osama Bari, Chief Technology Officer at D24 Fintech Group, exchanges that comply with a core set of rules will drastically reduce their chances of suffering a similar breach.

1. Multi-party approval systems

The Bybit security breach was primarily caused by vulnerabilities in multi-signature authorization and UI spoofing tactics, where attackers manipulated the interface to display different addresses. Bari said: “Even experienced professionals might overlook such discrepancies without a thorough investigation. Typically, such issues often go unnoticed during routine exchange operations.

“To mitigate such risks, exchanges should implement a threshold-based, multi-party approval system for all transactions.

“Additionally, secure platforms require real-time monitoring systems to analyze deposits and withdrawals, with automated cross-checks for unusual spikes. If required, large transactions must be manually verified with a comprehensive report. Each withdrawal should undergo a transaction audit score assessment before being processed.”

2. Ensure two-factor authentication is in place

Two-factor authentication (2FA) is a security method that requires a second form of identification to access any account information or funds.

Bari: “2FA is no new phenomenon, but its importance as a tool for verifying users and ensuring only the right personnel can manage and withdraw balances or view confidential information cannot be understated.

“This is a basic form of protection that exchanges should absolutely be offering to their customers and can be a vital deterrent for hackers as it increases the difficulty of breaching gated accounts. All financial providers have a duty to protect their users and 2FA is a guaranteed way of raising the level of in-built security they provide.”

3. Custodians are valuable third parties

Custodians safeguard assets for fellow financial institutions to reduce the risk of loss, theft, or damage.

Bari continued: “Exchanges should not underestimate the level of responsibility that comes with holding considerable volumes of assets on behalf of customers. Failure to put the appropriate measures in place to protect these funds, as we’ve just seen with the Bybit hack, could result in disastrous consequences for both the company attacked and the users impacted.

“Turning to external organizations to bolster security is a viable option for exchanges that lack the infrastructure and liquidity to manage millions, or even billions, worth of currency. Partnering with a trusted custodian will ensure that customer investments stay safe, allowing exchanges to focus on other important activities such as enhancing user experience and increasing the financial literacy of their customers.”

4. Perform a liveness check

A liveness check verifies a user’s identity through a biometric measure, for example, their face or fingerprint. 40% of banks have implemented this precaution to tackle fraud, up from 26% five years ago.

Bari: “For crypto exchanges, and financial institutions more generally, a liveness check adds that final layer of protection to dissuade hackers from attempting an attack. Having access to passwords, secure keys, or even primary devices is no longer enough to successfully bypass security measures—customers are protected as their face, fingerprints, and even voices are all unique.”

5. Make security CEXy

Centralized cryptocurrency exchanges (CEXs) are regulated intermediaries that facilitate the trading of fiat and digital currencies.

Bari concluded: “A pivotal element of cryptocurrency’s appeal throughout its history has been its decentralized nature, with many early adopters drawn to this form of tender by its anonymity. However, as crypto has become increasingly mainstream and a viable investment for individuals globally, it’s important to reshape our thinking and start putting security at the top of the list of priorities.

“Due to Bybit’s centralized approach, the exchange was able to freeze $42.85 million in stolen assets within 48 hours through collaborations with other platforms. This highlights the increased resilience of CEXs and how trusted partnerships with other organizations in the crypto field can limit the damage inflicted in a hack.”