Section 146

A taxable supply shall be deemed to take place in Nigeria where, in
supplies respect of –
(a) goods –
(i) the goods are physically present, imported into, assembled or installed
in Nigeria at the time of supply, or
(ii) the beneficial owner of the rights in or over the goods is a taxable
person in Nigeria and the goods or right is situated, registered or exercisable
in Nigeria;
(b) a service –
(i) the service is provided to and consumed by a person in Nigeria,
regardless of whether the service is rendered within or outside Nigeria
or whether or not the legal or contractual obligation to render such service
rests on a person within or outside Nigeria, or
(ii) the service is connected with existing immovable property, includ-
ing the services of agents, experts, engineers, architects and valuers,
where the property is located in Nigeria; and
(c) an incorporeal –
(i) the exploitation of the right is made by a person in Nigeria or whose
place of usual residence is Nigeria,
(ii) the right is registered in Nigeria, assigned to or acquired by, a
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person in Nigeria, regardless of whether the payment for its exploitation
is made within or outside Nigeria, or
(iii) the incorporeal is connected with a tangible or immovable asset
located in Nigeria.