International records / OpenAlex research

Taxing the Digital Workforce: Rethinking the Significant Economic Presence Rule Under Nigeria’s Tax Act 2025

The enactment of the Nigeria Tax Act (NTA) 2025 represents a significant restructuring of the nation’s fiscal framework, aimed at capturing value within the borderless digital economy. This study provides a legal analysis of the updated "Significant Economic Presence" (SEP) rule under Section 17 of the Act, which shifts the taxable nexus from traditional physical presence (Permanent Establishment) to economic participation. By expanding the SEP framework, the NTA 2025 formalises the "digital shadow" of the workforce, explicitly including remote freelancers, digital consultants, and content cre…