Nigeria: PwC Flags Ambiguities in Virtual Assets Tax Rules

What the report says

PwC Nigeria has said Nigeria’s new tax guidance on virtual assets brings a welcome first administrative framework but still leaves important legal and operational questions unresolved. The comments were made in a tax alert reviewed by Leadership and distributed by AllAfrica, following the Nigeria Revenue Service’s publication of Information Circular No. 2026/21 on July 31, 2026.

According to the firm, one major issue is a safe-harbour provision that exempts transfers between wallets owned by the same individual from tax. PwC said that rule does not extend to companies or partnerships, which could affect common treasury arrangements. It also noted uncertainty over how virtual asset prices should be determined because the rules refer to an NRS-approved price aggregator, but no public list of such aggregators appears to have been issued.

PwC further flagged the interaction between a one per cent withholding tax on certain disposals and income tax on gains, saying taxpayers and service providers may need careful reconciliation to avoid double counting. The guidelines also place duties on virtual asset service providers, including tax withholding, stamp duty collection, taxpayer identification verification, filing and record-keeping, with penalties for non-compliance.

The report said stakeholders remain split on the new regime. Some see it as clearer regulation for a fast-growing digital asset market, while others fear it could raise compliance costs and slow innovation. The guidelines follow President Bola Tinubu’s 2026 executive order on virtual assets coordination, which signaled a broader move toward regulation of crypto and related digital products.