When can a foreign-incorporated company be treated as a Nigerian company under the 2025 reforms?

According to @tax-reform, a company can fall into the Nigerian-company net even if it is incorporated abroad where its central or effective place of management or control is in Nigeria, which can expose global income to Nigerian tax subject to treaty or unilateral relief.

The source paper treats this as one of the most consequential changes in the reform package because it shifts the residence test away from incorporation alone. The same paper also cautions that its analysis is based on the most recent publicly available drafts, so businesses should read this rule together with any later gazetted text and implementation guidance.