Nigeria, Netherlands Begin Renegotiation of Double Taxation Treaty in Line with New Tax Reforms

Nigeria and the Kingdom of the Netherlands have officially commenced the renegotiation of their longstanding Double Taxation Agreement (DTA), aligning it with recent developments in Nigeria’s tax laws and evolving global standards.

The talks were formally opened at a ceremony hosted by Dr. Zacch Adedeji, Executive Chairman of the Federal Inland Revenue Service (FIRS), at the Revenue House in Abuja. The Dutch delegation was led by His Excellency Bengt van Loosdrecht, Ambassador of the Netherlands to Nigeria.

The current DTA between both countries—titled “Agreement between the Kingdom of the Netherlands and the Federal Republic of Nigeria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains”—has been in place since 1991.

The renegotiation comes on the heels of Nigeria’s sweeping fiscal overhaul, following the signing of the Tax Reform Act by President Bola Ahmed Tinubu (GCFR) on June 26, 2025. The revised tax framework has sparked interest from global partners, with the Netherlands becoming the first foreign government to initiate formal talks in response to the reforms.

In his opening remarks, Dr. Adedeji underscored the significance of the engagement:

“Recent developments in both domestic and international tax regimes—especially Nigeria’s current tax reforms and global efforts such as the Base Erosion and Profit Shifting (BEPS) initiative—make the review of our existing treaty imperative.”

He described the renegotiation as part of Nigeria’s broader agenda to modernize its tax system, expand the domestic tax base, and improve transparency and fairness.

“This process reflects our government’s commitment to building a more inclusive and growth-oriented tax system. We aim to create agreements that are up-to-date, equitable, and reflective of our national interest and global obligations.”

The revised agreement is expected to eliminate outdated provisions and better address issues of fiscal evasion, tax avoidance, and investment protection under current realities.

Speaking on behalf of the Dutch delegation, Ambassador van Loosdrecht praised the collaborative atmosphere of the meeting, stressing mutual respect and professionalism on both sides.

“That we are here today is a testament to the goodwill and trust between our nations. I can assure you that my colleagues from the Netherlands are committed to negotiating in good faith. Ultimately, a treaty is about identifying and building on shared interests, and I’m confident our teams will achieve that.”

He expressed optimism about the outcome of the negotiations, describing the week-long talks as a critical opportunity to strengthen the economic relationship between Nigeria and the Netherlands.

The renegotiation is expected to pave the way for more equitable tax arrangements that foster investment, transparency, and cross-border economic cooperation—reinforcing both countries’ commitment to a fair international tax system.