Section 147

(1) For the purposes of Chapter Six of this Act, a taxable supply Time of
shall be deemed to take place at the time an invoice or receipt is issued by the Supply
supplier, or where goods are delivered or made available for use, or payment is
due to or received by the supplier in respect of that supply, whichever occurs
first.
(2) A taxable supply shall be deemed to take place where the supplier
and recipient are connected persons and invoices are not issued, in the case of
–
(a) a supply of goods which are to be removed, the time of removal of
the goods;
(b) a supply of goods which is not to be removed at the time when they
are available to the recipient;
(c) furnishing of a service, upon commencement of the furnishing of the
service; or
(d) an incorporeal, when such incorporeal becomes available for the use
of the recipient.
(3) Notwithstanding the provisions of subsections (1) or (2) –
(a) where goods are supplied under any rental agreement or where
services are furnished under any agreement or law which provides for
periodic payments, they shall be deemed to be successively supplied for
successive parts of the periods of the agreement or as determined by such
law, and each of the successive supplies shall be deemed to occur when
payment becomes due or is received, whichever is earlier;
(b) where, and to the extent that, taxable supplies are –
(i) progressively or periodically made under any agreement or law
which provides for the consideration for that supply to be paid in instalments
or periodically and in relation to the progressive or periodic supply, or
(ii) made in relation to any construction, assembly, manufacturing,
alteration, improvement or repair activity under any agreement or law
which provides for the consideration for that supply to become due and
payable in instalments or periodically in relation to the progressive nature
of the work,
the supplies shall be deemed to be successively made, and each succes-
sive supply shall be deemed to take place whenever any payment becomes
due or is received or an invoice relating to only that payment is issued,
whichever occurs first; and
A 472 2025 No. 7 Nigeria Tax Act, 2025
(c) where a taxable supply is made under an instalment credit agreement,
the supply shall be deemed to take place at the time the taxable supply is
delivered or the time any payment of consideration is received by the supplier
in respect of the supply, whichever occurs first.