The Resource Taxing the income of digital non-resident companies under the "Significant Economic Presence" (SEP) rules In Nigeria

Taxing the income of digital non-resident companies under the "Significant Economic Presence" (SEP) rules In Nigeria

Label
Taxing the income of digital non-resident companies under the "Significant Economic Presence" (SEP) rules In Nigeria
Title
Taxing the income of digital non-resident companies under the "Significant Economic Presence" (SEP) rules In Nigeria
Creator
Subject
Language
eng
Summary
In January 2020, Nigeria amended its corporate tax rules to introduce the significant economic presence (SEP) as an additional basis for taxing digital non-resident companies (NRCs) with Nigerian sourced income. This amendment follows attempts at reforming international tax rules by the United Nations (UN), European Union (EU), and G20 / Organization for Economic Cooperation and Development (OECD). The G20/OECD's Action 1 of the Base Erosion and Profit Shifting (BEPS) Project and the Inclusive Framework for BEPS seek to provide policy suggestions for aligning the place of taxation with that of value creation. This article examines the scope of the SEP and its suitability, workability, and sustainability for taxing digital NRCs in Nigeria, review judicial decisions on taxation of digital NRCs, and analyse the enforcement challenges of the SEP in the context of Nigeria's digital and wider economy
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 49 (2021), no. 5 ; p. 447-463
http://library.link/vocab/creatorName
Obayemi, O
Geographic coverage
Africa
Language note
English
http://library.link/vocab/subjectName
  • non-resident company
  • significant economic presence
  • digital economy
  • source of income
  • value creation
  • PE
  • allocation of taxing rights
  • BEPS Project (OECD)
  • case law
  • enforcement
Label
Taxing the income of digital non-resident companies under the "Significant Economic Presence" (SEP) rules In Nigeria
Instantiates
Publication
Label
Taxing the income of digital non-resident companies under the "Significant Economic Presence" (SEP) rules In Nigeria
Publication

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