Section 6

(1) The profits of a Nigerian company are deemed to accrue in Nigeria
Nigerian
company wherever the profits arise and whether or not such profits have been brought
into or received in Nigeria.
(2) Where a foreign company which is controlled by a Nigerian company
has not, in a year, distributed profits to its shareholders, the proportion of the
profits of the controlled foreign company attributable to the Nigerian company,
which could have been distributed without detriment to the company's business
shall be construed as distributed and included in the profits of the Nigerian
company for the purposes of subsection (1).
(3) Where the income tax paid by a non-resident company which is a
subsidiary of a Nigerian company or a member of a multinational group of a
Nigerian company in any year yields less than the minimum effective tax rate
prescribed by this Act, the Nigerian parent company shall pay an amount to
make that non-resident subsidiary's income tax equal to the minimum effective
tax rate.
(4) The Service shall provide detailed rules for the implementation of
subsections (2) and (3).
Nigerian divi- 7. (1) Nigerian dividends include –
dends
(a) dividend distributed by a Nigerian company, and shall be the gross
amount of that dividend before any deduction; and
(b) any amount of the undistributed profit of a Nigerian company, which
is treated as distributed under the provisions of any law in Nigeria.
(2) The income from a dividend distributed by a Nigerian company is
deemed to arise on the day on which payment of that dividend becomes due.
Nigeria Tax Act, 2025 2025 No. 7 A 397