PwC warns of costly uncertainty over e-invoicing rules for foreign digital platforms in Nigeria

Foreign digital companies providing services to Nigerian customers may be uncertain as to how they are to comply with Nigeria’s e-invoicing rules, according to a new PwC report which points to a lack of guidance for companies based overseas.

PwC’s report, VAT in Africa: Digital Services 2026, notes that Nigeria’s tax rules cover foreign companies supplying taxable digital services to Nigerian customers. However, it says there is uncertainty about how those companies should comply with the country’s e-invoicing requirements.

E-invoicing involves creating and managing invoices electronically, allowing tax authorities to monitor transactions and check whether businesses are paying the correct taxes.

The uncertainty comes as Nigeria introduces new tax laws, including the Nigerian Tax Act and the Nigerian Tax Administration Act, which form part of a broader overhaul of the country’s tax system.

PwC states what the problem is

Nigeria’s electronic invoicing system aims to improve tax monitoring and compliance. The rules generally apply to taxable transactions by both local and foreign businesses, but PwC points out that it is still unclear how non-resident digital service providers should follow these requirements in practice.

Starting in February 2026, the Nigeria Revenue Service (NRS) made e-invoicing mandatory only for large taxpayers with an annual turnover of at least ₦5 billion.

However, PwC notes that the NRS had not expressly excluded foreign digital service providers from this category. This leaves questions about whether some of these companies could fall within the rules and what steps they would need to take.

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PwC advises affected businesses to contact the NRS and request written clarification on whether they must comply and whether penalties could apply. The report does not say that all foreign digital platforms are exempt from e-invoicing. Instead, it points to uncertainty over how the requirements apply to them.

The VAT rules already cover digital services

E-invoicing is a different matter from the requirement to collect and pay value-added tax (VAT) on digital services in Nigeria. While both relate to tax, they are handled through separate rules.

If you are a foreign company providing digital services to customers in Nigeria, you need to register for VAT once your annual sales reach, or are expected to reach, $25,000 (or the equivalent in other currencies). Nigeria charges a standard VAT rate of 7.5%.

The rules cover services such as streaming and downloadable content, online advertising, cloud storage, online gaming, digital education, subscription-based social media, online marketplaces and ride-hailing platforms. For example, a foreign company selling a taxable digital subscription to a Nigerian customer may be required to charge VAT on the transaction and remit it to the NRS.

Registered providers must obtain a tax identification number, issue tax invoices, file monthly VAT returns and remit the tax by the 21st day of the following month. The rules also affect business-to-business transactions. If a foreign supplier fails to charge VAT on a taxable service sold to a Nigerian business, the Nigerian customer may have to calculate and remit the tax itself.

PwC says Nigeria’s simplified VAT compliance circular, which took effect in January 2022, remains relevant while the country awaits an updated circular reflecting the newer tax legislation. For foreign digital companies, the key question is how to meet their existing tax obligations while navigating the newer rules and any applicable e-invoicing requirements.

See also: Nigeria’s ICT sector grows 10.98% as broadband, AI investments rise – PwC