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Nigeria: Share-purchase agreements are subject to stamp duties

Taxpayer ordered to pay 10% per annum interest on the unpaid duty until fully settled. 

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January 29, 2026

The Lagos Zone of the Tax Appeal Tribunal (TAT) in November 2025 held that share-purchase agreements are subject to stamp duties.

The case is: Oando Oil Limited v. Federal Inland Revenue Service (FIRS)

The Tribunal upheld the FIRS's assessment of approximately U.S. $88 million in stamp duties, stating that the agreements were share-purchase contracts, not exempt share transfers, and ordered the taxpayer to pay 10% per annum interest on the unpaid duty until fully settled.


For more information, contact a KPMG tax professional in Nigeria:

Olufemi Babem | olufemi.babem@ng.kpmg.com

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