PwC Nigeria said the new framework could significantly alter how digital-asset businesses operate as authorities move towards bringing the sector more firmly within the formal tax system.
The Nigeria Revenue Service (NRS) issued Information Circular No. 2026/21, titled Guidelines on the Taxation of Virtual Assets, on July 31, 2026. According to PwC, the document provides Nigeria’s first comprehensive administrative framework for the taxation of virtual assets.
The accounting and professional services firm said the guidelines come at a time when digital-asset activities are becoming an increasingly important part of the Nigerian economy. It described the development as another indication that the government’s approach to virtual assets is shifting from restrictions towards greater formalisation and regulatory oversight.
However, PwC raised questions about the timing and legal basis of some of the requirements. It noted that the guidelines do not state an effective date, even though some of the obligations introduced are not expressly provided for under the Nigeria Tax Act (NTA) or the Nigeria Tax Administration Act (NTAA).
This could create uncertainty for VASPs and other market participants as they seek to determine when and how the new compliance requirements should be implemented.
PwC also highlighted the possibility of multiple tax liabilities arising from a single virtual-asset transaction. Depending on the nature of the transaction and the specific taxable event, one transaction could potentially attract more than one form of tax.
The firm particularly drew attention to the guidelines’ treatment of stamp duty. PwC said the position taken by the NRS could potentially result in a wider 1.5 per cent stamp-duty exposure on transactions involving the transfer of goods and intangible property.
At the same time, PwC pointed out that transactions valued at N10 million or less should, based on the applicable law, be exempt from stamp duty. It therefore urged the NRS and VASPs to take this threshold into account when developing or configuring their transaction and compliance systems.
The development places greater responsibility on digital-asset platforms to understand the tax treatment of different transactions and ensure that their systems can accurately identify, calculate and report applicable liabilities.
For Nigeria’s growing virtual-asset industry, the guidelines could therefore mark an important stage in the transition towards a more structured tax and regulatory environment, while also raising questions around implementation, legal certainty and the practical compliance burden on market participants.