PwC Nigeria has said Nigeria’s new tax guidelines for virtual assets provide welcome clarity but leave practical and legal uncertainties that could complicate compliance for taxpayers and service providers.
In a tax alert titled “Taxing the intangible: A critical analysis of the NRS guidelines on taxation of virtual assets”, the firm welcomed the Nigeria Revenue Service’s (NRS) first comprehensive administrative framework on virtual assets, published on July 31, 2026 as Information Circular No. 2026/21.
The guidelines classify virtual assets into six categories, covering cryptocurrencies such as Bitcoin and Ether, stablecoins, security and investment tokens, utility and governance tokens, non-fungible tokens, and sovereign digital currencies.
PwC said the framework provides taxpayers with “much needed clarity” on which digital assets fall within or outside the scope of taxation and reporting.
It also described the dollar-referenced methodology for calculating gains as a “welcome and pragmatic policy choice”, as it excludes gains arising purely from naira depreciation.
However, the firm highlighted several areas of uncertainty, including the NRS position that transfers of property are subject to 1.5% stamp duty and whether the agency can impose withholding tax outside the WHT Regulations 2024.
Virtual Asset Service Providers (VASPs) are required to withhold tax on disposals, deduct stamp duty in token units, enforce Tax ID requirements, and file comprehensive returns, effectively making them primary tax collectors in the ecosystem.
PwC also identified an enforcement gap around off-platform peer-to-peer transactions, which rely on taxpayers’ annual self-assessment.
Other ambiguities include a wallet-transfer safe harbour that applies only to individuals, reliance on an unpublished list of NRS-approved price aggregators, and the need to reconcile withholding tax on gross proceeds with income tax on net gains to avoid over-taxation.
PwC said taxpayers should urgently obtain Tax IDs, while VASPs should review their systems to ensure they can compute, withhold and remit taxes as required.
“While implementation challenges remain, the Guideline provides a workable baseline for compliance,” PwC said.
