Nigeria, Netherlands begin talks on renegotiation of double taxation agreement

Nigeria and the Kingdom of the Netherlands have formally commenced negotiations to review and update their existing tax agreement, marking a key step in aligning bilateral tax relations with Nigeria’s newly signed tax reforms.

The talks follow President Bola Ahmed Tinubu’s signing of the Tax Reform Bill into law on June 26, 2025, and reflect growing international engagement with Nigeria’s evolving tax framework.

The Netherlands, one of Nigeria’s long-standing trade and investment partners, is the first foreign government to begin formal discussions aimed at modernising the agreement, particularly provisions on double taxation that no longer reflect current global or domestic realities.

Zacch Adedeji, executive chairman of the Federal Inland Revenue Service (FIRS), hosted the Dutch delegation led by Bengt van Loosdrecht, Ambassador of the Kingdom of the Netherlands to Nigeria, at the Revenue House in Abuja for the opening ceremony of the renegotiation.

Welcoming the delegation on behalf of the President, Government, and people of Nigeria, Adedeji described the talks as timely, given the shifting tax environment both locally and internationally. “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Erosion and Profit Shifting (BEPS), and other evolving international tax standards will render the extant agreement out-of-date,” he said.

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Adedeji further emphasised that the discussions align with the Tinubu administration’s broader reform agenda. “This renegotiation meets with the policy objectives of the ongoing fiscal and tax reforms initiated by the administration of President Bola Ahmed Tinubu. We are committed to broadening the domestic tax base, strengthening tax administration, and ensuring that our tax system supports inclusive economic growth.”

In his response, Ambassador van Loosdrecht expressed gratitude for the warm reception and noted the strong spirit of cooperation between both countries. “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 stated.

He expressed optimism about the process and confidence in the teams involved, saying, “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 tax reform bills recently enacted include the Nigeria Tax Act, the Nigeria Tax Administration Act, the Nigeria Revenue Service (Establishment) Act, and the Joint Tax Board (Establishment) Act. These laws restructure Nigeria’s tax framework and administration.

The next six months will be used to harmonise tax data, implement the new laws, and establish the systems needed for the January 1, 2026, launch of the Nigeria Revenue Service. During this transition period, existing international tax treaties will be reviewed to ensure full alignment with Nigeria’s reformed tax structure.