As Nigeria’s wealth transfer landscape evolves with the enactment of the Nigeria Tax Act, 2025 (NTA 2025), understanding the new tax obligations associated with succession is crucial for families. Executors, trustees, and heirs must now navigate a complex framework that extends beyond traditional customs and inheritance rituals.
The importance of comprehensive estate planning cannot be overstated. Executors must ensure that all assets are meticulously documented within the estate plan. Any oversight can lead to significant complications, especially in light of the new regulations. Similarly, the treatment of offshore trusts has transformed under the NTA 2025, requiring a thorough understanding of how these entities are taxed and their implications for family wealth.
Undocumented ancestral property presents another challenge. The NTA 2025 specifies clear obligations regarding such assets, making it imperative for families to clarify their status to avoid unforeseen tax liabilities.
The NTA 2025 mandates that every succession pathway—whether through a will, trust, or intestacy—carries specific tax responsibilities. Executors are now tasked with settling both the deceased’s final income taxes and any estate income during the probate process. This shift effectively positions them as tax administrators, bearing personal liability for any errors or omissions. Delays in probate can further exacerbate exposure, as all estate income remains taxable until assets are distributed.
Trustees must also adapt to new requirements, including maintaining accurate accounts and filing annual returns. The introduction of a “look-through” attribution rule means that income may be attributed back to the settlor when control or benefits are retained, compelling trustees to navigate a more complex compliance landscape.
In cases of intestacy, administrators face similar obligations to executors but often contend with longer timelines. This can erode the value of the estate as taxable income accumulates during probate delays. For families with international ties, the NTA 2025 introduces additional complexities. Nigerian residents are taxed on their worldwide income, while non-residents remain liable for Nigerian assets. Without treaty relief, heirs may be vulnerable to double or even triple taxation.
The implications of the NTA 2025 for family wealth planning are profound. As succession has transformed into a tax event rather than merely a family affair, strategic planning is essential. Families must safeguard their assets, reduce the risk of double taxation, and ensure compliance with both domestic and international tax laws.
To explore these topics further, we invite you to join our Real Estate Tax Master Class beginning November 7, 2025, in Lagos. This workshop will provide invaluable insights into navigating the new NTA era, featuring practical scenarios and comprehensive tax compliance strategies. Early Bird Registration is open until October 17, 2025, and spaces are limited. Secure your spot today at [RIRFHUD Master Class].
