Nigeria: Share-purchase agreements are subject to stamp duties
Taxpayer ordered to pay 10% per annum interest on the unpaid duty until fully settled.
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