Nigeria, Netherlands Begin Tax Treaty Renegotiation

By Oluwakemi Kindness

The Federal Government of Nigeria has officially opened talks with the Kingdom of the Netherlands to renegotiate their Double Taxation Agreement (DTA).

This marks the first international tax treaty review since the enactment of sweeping tax reforms signed into law by President Bola Tinubu on June 26, 2025.

The milestone event, held at the Revenue House in Abuja, was hosted by the Executive Chairman of the Federal Inland Revenue Service (FIRS), Dr. Zacch Adedeji, who received the Dutch delegation led by Ambassador Bengt van Loosdrecht.

The renegotiation signals growing global engagement with Nigeria’s overhauled tax regime and sets the tone for future treaty updates aimed at aligning existing agreements with modern tax realities, including new measures to curb Base Erosion and Profit Shifting (BEPS).

Speaking on behalf of President Tinubu and the Nigerian government, Chairman of FIRS, Dr. Zacch Adedeji, described the review as “unavoidable” in light of recent domestic and international tax developments.

According to a statement on Monday by the Service, he notes that the initiative reflects Nigeria’s commitment to a transparent, inclusive, and forward-looking fiscal environment.

“This renegotiation meets with the policy objectives of the ongoing fiscal and tax reforms initiated by the administration of President Bola Ahmed Tinubu,” Adedeji said.

“We are committed to broadening the domestic tax base, strengthening tax administration, and ensuring that our tax system supports inclusive economic growth.”

For Ambassador van Loosdrecht, he praised the collaborative spirit guiding the negotiations, describing the meeting as a reflection of goodwill and mutual respect.

He expresses confidence in the professionalism and shared objectives of both sides.

“Ultimately, a treaty is about finding common ground and building upon it,” he said. “I know both of our sides have very competent, professional teams, and I am confident we will have a very fruitful week.”

The current talks are expected to replace outdated provisions in the existing tax treaty, especially those inconsistent with Nigeria’s newly signed legislation: the Nigeria Tax Act, the Nigeria Tax Administration Act, the Nigeria Revenue Service (Establishment) Act, and the Joint Tax Board (Establishment) Act.

The renegotiation comes as Nigeria begins a six-month transition phase, during which key systems will be harmonized ahead of the January 1, 2026, launch of the new Nigeria Revenue Service.

Existing tax treaties will also be reviewed during this period to ensure consistency with the country’s renewed fiscal architecture.