Nigeria and Netherlands Commence Renegotiation of Double Taxation Agreement

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The Federal Inland Revenue Service (FIRS) and the Kingdom of the Netherlands have commenced the renegotiation of the Double Taxation Agreement between Nigeria and the Netherlands. The move marks the beginning of a new phase in Nigeria’s international tax relations, following the signing of the Tax Reform Bills into law by President Bola Tinubu in June 2025.

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FIRS Executive Chairman, Dr Zacch Adedeji, welcomed the delegation from the Netherlands, led by the nation’s ambassador to Nigeria, FIRS Director of Corporate Communications, in a statement. Adedeji described the visit as timely, considering recent changes in both domestic and global tax systems.

Recent Tax Reforms Drive Renegotiation

The renegotiation is driven by recent developments in the domestic and global tax landscape, including tax reforms carried out by the Nigerian government and global measures against base erosion and profit shifting. Adedeji stated, “Recent developments in the domestic and global tax landscape have made the review of the existing agreement unavoidable. Particularly, the tax reforms being carried out by our government, global measures against base erosion and profit shifting and other evolving international tax standards will render the extant agreement out of date.

The FIRS Executive Chairman emphasised that the discussions align with the policy direction of the current administration and reflect Nigeria’s commitment to a transparent and fair process. “This renegotiation meets with the policy objectives of the ongoing fiscal and tax reforms initiated by the administration of President Bola Tinubu. We are committed to broadening the domestic tax base, strengthening tax administration, and ensuring that our tax system supports inclusive economic growth,” Adedeji affirmed.

Optimism for Fruitful Negotiations

The Ambassador of the Kingdom of the Netherlands to Nigeria, Bengt van Loosdrecht, expressed appreciation for the warm welcome and highlighted the spirit of cooperation guiding the negotiations. “The fact that we meet here today is an indication of the goodwill and the good faith in which we want to meet with each other. And I can assure you that my colleagues from the Netherlands will act in good faith. That is always an important basis for good negotiations,” he said.

Van Loosdrecht expressed optimism about the process and the teams involved, stating, “Ultimately, a treaty is about finding common ground and building upon that common ground. I know both of our sides have very competent, professional teams, and I am confident we will have a very fruitful week.”

The FIRS has stated that the next six months will be used to harmonise tax data, implement the newly signed laws, and put systems in place ahead of the January 1, 2026, takeoff of the Nigeria Revenue Service. This transition period will also cover the review of existing tax agreements to ensure they reflect the provisions of the new reforms

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