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Global professional services firm, PricewaterhouseCoopers (PwC), has raised concerns over uncertainty surrounding Nigeria’s electronic invoicing requirements for foreign digital service providers, warning that the lack of clear guidance could complicate tax compliance for international technology companies operating in the country.
In its report, VAT in Africa: Digital Services 2026, PwC noted that although Nigeria’s tax framework covers foreign companies supplying taxable digital services to Nigerian customers, questions remain about how non-resident businesses should comply with the country’s e-invoicing rules.
The development comes amid Nigeria’s ongoing tax reforms, including the Nigerian Tax Act and the Nigerian Tax Administration Act, which are part of efforts to strengthen tax administration and improve revenue collection.
Electronic invoicing, or e-invoicing, involves the electronic generation and management of invoices, enabling tax authorities to monitor business transactions and improve tax compliance.
According to the report, Nigeria introduced mandatory e-invoicing from February 2026 for large taxpayers with annual turnover of at least N5 billion.
However, PwC observed that the Nigeria Revenue Service (NRS) had not expressly excluded foreign digital service providers from the category of taxpayers covered by the requirement.
This has created uncertainty over whether non-resident companies meeting the relevant criteria are required to comply and what procedures they should follow.
The firm advised affected businesses to seek written clarification from the NRS on their obligations and whether penalties could apply for non-compliance.
PwC’s position does not mean that foreign digital platforms are automatically exempt from the requirements. Rather, it highlights the need for clearer guidance on how the rules apply to companies operating from outside Nigeria.
The uncertainty could affect international technology businesses providing services such as cloud computing, online advertising, streaming, digital subscriptions and other internet-based services to Nigerian customers.
PwC clarified that uncertainty surrounding e-invoicing does not remove existing value-added tax (VAT) obligations for foreign digital service providers.
Under Nigeria’s digital services VAT framework, foreign companies supplying taxable services to Nigerian customers are required to register for VAT when their annual sales reach, or are expected to reach, $25,000 or its equivalent in other currencies.
Nigeria’s standard VAT rate is 7.5 per cent.
The rules cover a broad range of digital services, including online advertising, cloud storage, downloadable content, online gaming, digital education, subscription-based social media services, online marketplaces and ride-hailing platforms.
Registered providers are required to obtain a tax identification number, issue tax invoices, submit monthly VAT returns and remit the tax collected by the 21st day of the following month.
The obligations also extend to business-to-business transactions. Where a foreign supplier fails to charge VAT on a taxable service supplied to a Nigerian business, the local customer may be required to account for and remit the tax.
PwC further noted that Nigeria’s simplified VAT compliance circular, which took effect in January 2022, remains relevant pending the issuance of updated guidance reflecting the country’s newer tax legislation.
The firm said foreign digital service providers must therefore continue to meet their existing VAT obligations while seeking clarity on how the e-invoicing requirements apply to their operations.
The concerns highlight the importance of clear regulatory guidance as Nigeria expands digital taxation and strengthens oversight of transactions involving foreign technology companies.
For international digital businesses serving the Nigerian market, clarity on the scope of e-invoicing requirements, compliance procedures and possible penalties would help reduce uncertainty and support adherence to the country’s evolving tax framework.
