PricewaterhouseCoopers has raised concerns over a lack of clarity on how Nigeria’s electronic invoicing requirements for value added tax apply to foreign companies supplying digital services to customers in the country.
PwC highlighted the issue in its VAT in Africa: Digital Services 2026 report released on Tuesday, which reviews digital tax regimes across 28 African countries.
“Although the legal and policy framework suggests that non-resident suppliers fall within scope, the NRS is yet to clearly define the operational requirements applicable to such entities,” PwC said.
As of February 2026, mandatory e-invoicing in Nigeria applied to large taxpayers with annual turnover of at least N5 billion, according to the report. PwC said it remained unclear how the requirements should be implemented by non-resident suppliers.
The firm advised affected companies to seek clarification from the Nigeria Revenue Service while preparing for possible implementation of the requirements.
Nigeria’s digital VAT framework covers services including online advertising, cloud computing, software and applications, streaming platforms, digital marketplaces and other automated online services.
PwC said non-resident businesses that meet Nigeria’s VAT registration requirements are expected to collect VAT on taxable supplies to Nigerian customers and remit the money to the NRS.
The tax is required to be remitted before the 21st day of the month following the relevant transactions. Where a foreign supplier fails to collect VAT on a taxable supply, the Nigerian customer may be required to account for the tax.
Eligible foreign suppliers can also offset allowable input VAT incurred on services and fixed assets used to provide taxable supplies in Nigeria against the output VAT they collect, the report said.
Nigeria’s approach forms part of a wider push by African governments to capture tax revenue generated by the rapidly expanding digital economy.
PwC found that 32 of Africa’s 54 countries now have VAT or other indirect tax rules covering electronic services supplied by foreign businesses, compared with 21 countries in 2024.
“Tax policymakers across Africa have taken decisive notice of the revenue mobilisation potential and trade distortions,” the firm said.
Algeria, Botswana, Chad, the Republic of Congo, Liberia, Malawi, Mauritania, Mauritius, Rwanda, Togo and Zanzibar are among jurisdictions that have introduced relevant rules since PwC’s first edition of the publication in 2024.
Governments are seeking to address a tax gap created when digital companies generate revenue from customers in a country without maintaining a physical presence there.
“The value is consumed locally, but the supplier has no physical presence, no local establishment,” PwC said.
The firm warned that failing to impose comparable tax obligations on foreign digital businesses could deprive governments of revenue while placing domestic companies at a competitive disadvantage.
“The failure to extend the same obligation to non-resident digital suppliers creates distortions, undermines tax neutrality and deprives governments of revenue that is rightly due,” the report stated.
Despite the growing number of countries introducing digital tax rules, PwC said Africa still lacks a harmonised approach.
Requirements differ over registration thresholds, invoicing, filing procedures and the types of transactions subject to tax. Some jurisdictions distinguish between services supplied to businesses and those sold directly to consumers, while others do not.
Those differences can leave companies operating across several African markets dealing with separate registration systems, filing deadlines and documentation requirements.
PwC Africa Tax and Legal Services Leader Job Kabochi said electronically supplied services were becoming increasingly important across the continent as digital technology transforms areas including education, healthcare and business operations.
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