Section 121

(1) Where the Government of the Federal Republic of Nigeria
Double
taxation enters into an agreement with a treaty partner for the purpose of providing
agreement relief from double taxation in relation to tax imposed under this Act, the agree-
ment shall have effect upon ratification or domestication by the National As-
sembly.
(2) Relief from double taxation shall be in respect of income tax paid
under the laws of a treaty partner against income taxes imposed under this
Act.
(3) Where an agreement has taken effect, any obligation as to secrecy in
Nigeria Tax Administration Act, 2025 or any other law in Nigeria shall not
prevent the disclosure of any information required to be disclosed under the
agreement to an authorised officer of a treaty partner.
(4) The Minister may make rules for implementing the provisions of any
agreement under this section.
(5) For the purposes of providing relief in Nigeria from double taxation,
all extant double taxation agreements are deemed to have been made under
the provisions of this section and shall apply throughout Nigeria with effect
from 1 January of the year immediately following the date the agreement
entered into effect.
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(6) The agreement in subsection (1) shall be for the purpose of elimination
of double taxation, without creating opportunities for non-taxation or reduced
taxation through tax evasion, avoidance or other forms of abuse, including
treaty-shopping arrangements aimed at obtaining reliefs provided in the
agreement for the indirect benefit of residents of any other country or territory
that is not part of the agreement.
(7) For the purposes of the agreement referred to in subsection (1), a
non-resident may benefit under the agreement where the person is a resident
of the relevant treaty partner and the beneficial owner of the income for which
the benefit is being claimed.
(8) Nothing in this section shall be construed to allow a relief in respect
of an additional tax paid for the relevant tax year under this Act or the domestic
legislation of a treaty partner in conformity with the global minimum tax rules
as it relates to a permanent establishment situated in the treaty partner.