V.O. Atanda Finlogix

V.O. Atanda Finlogix

As we entered the second half of 2026, I asked myself a critical portfolio allocation question:Which Nigerian stock offe...
01/07/2026

As we entered the second half of 2026, I asked myself a critical portfolio allocation question:

Which Nigerian stock offers the best risk-adjusted opportunity for investment?

Rather than starting with individual companies, I adopted a top-down stock picking approach.

I began with the macroeconomic environment.

Nigeria’s current economic landscape presents a unique setup: persistent high policy rates, ongoing banking recapitalization, inflationary pressures, and continued market repricing. These factors raised an important question:

Which sector stands to benefit the most from current macro conditions?

After screening major sectors on the Nigerian Exchange Group, the banking sector stood out.

Why?

✔ Higher interest rates continue to support Net Interest Margins (NIM) and interest income
✔ Recapitalization is strengthening balance sheets and long-term lending capacity
✔ Sector earnings remain resilient despite macro volatility
✔ Valuation multiples still suggest selective mispricing opportunities

The next question became:

Tier-1 banks or Tier-2 banks?

While FUGAZ banks offer stability and quality, much of that strength appears already priced in.

I found stronger alpha generation opportunities within Tier-2 banking stocks, where pricing inefficiencies and limited institutional coverage create wider valuation gaps.

This led me to build a focused basket I call FSWSF:

💫 FCMB Group Plc
💫 Fidelity Bank Plc
💫 Wema Bank Plc
💫 Sterling Financial Holdings Company Plc
💫 Stanbic IBTC Holdings Plc

Using relative valuation techniques based on:

✔ P/E Ratio
✔ Price-to-Book (P/B)
✔ EPS
✔ 5-Year EPS Growth
✔ Dividend Yield

I ranked the FSWSF banking universe to identify the strongest opportunity.

Final Ranking:

🥇 FCMB — Best Pick
🥈 Fidelity Bank — Strong Buy
🥉 Wema Bank — Buy
4️⃣ Stanbic IBTC — Hold
5️⃣ Sterling Financial Holdings — Avoid / Weak

Why FCMB?

FCMB emerged as my top pick due to its:

✔ Lowest P/E ratio (2.41x)
✔ Lowest P/B ratio (0.58x)
✔ Strong margin of safety
✔ Attractive upside potential from valuation re-rating

In my view, FCMB currently offers the strongest combination of deep value, resilience, and re-rating potential among Tier-2 Nigerian banking stocks.

I have attached my full Top-Down Relative Valuation Stock Pick Report.

If you had to allocate capital to one Nigerian banking stock for H2 2026, which would you choose and why?

Disclaimer: This report reflects personal analysis based on publicly available data as of June 30, 2026, and should not be construed as financial or investment advice.

📊 FUGAZ Banking Stocks Valuation & Seasonal Price Trend AnalysisDuring my study session today, I carried out a valuation...
21/06/2026

📊 FUGAZ Banking Stocks Valuation & Seasonal Price Trend Analysis

During my study session today, I carried out a valuation and seasonal price trend analysis on Nigeria’s Tier-1 banking stocks (FUGAZ): FirstHoldCo, UBA, GTCO, Access Holdings, and Zenith Bank.

My analysis suggests Access Holdings currently offers the most attractive risk-reward opportunity, with an estimated 74.7% upside to fair value, supported by:
• Lowest P/E multiple (1.67x) among peers
• Strongest 5-year EPS growth (35.51%)
• Attractive dividend yield (10.64%)

UBA also stands out as a BUY, with 68.5% upside, supported by improving earnings growth and relatively cheap valuation.

GTCO remains a high-quality banking play with 38.9% upside, combining strong earnings resilience with the highest dividend yield (9.47%) among FUGAZ banks.

FirstHoldCo shows moderate upside of 26.7%, making it more of a Hold / Accumulate candidate than an aggressive buy.

Zenith Bank, however, appears to be trading above my model-implied fair value, suggesting a 31.6% downside, which supports a Hold / Reduce stance despite its strong fundamentals.

📌 Recommendation Summary
• Strong Buy: Access Holdings
• Buy: UBA, GTCO
• Hold / Accumulate: FirstHoldCo
• Hold / Reduce: Zenith Bank

Disclaimer: This analysis reflects my personal valuation framework using seasonal trend analysis, earnings, valuation multiples, and dividend metrics. It is for informational purposes only and should not be construed as investment advice.



https://surl.li/fkonrp

📊 𝗠𝗔𝗥𝗞𝗘𝗧 𝗨𝗣𝗗𝗔𝗧𝗘 — 𝗦𝗧𝗔𝗡𝗕𝗜𝗖 𝗜𝗕𝗧𝗖Stanbic IBTC Holdings Plc surged by 9.70% to close at N181, up from N165, effectively meet...
04/05/2026

📊 𝗠𝗔𝗥𝗞𝗘𝗧 𝗨𝗣𝗗𝗔𝗧𝗘 — 𝗦𝗧𝗔𝗡𝗕𝗜𝗖 𝗜𝗕𝗧𝗖

Stanbic IBTC Holdings Plc surged by 9.70% to close at N181, up from N165, effectively meeting our projected 7%–10% weekly upside target within a single session. The strong close reflects sustained buying pressure and confirms continued momentum within the prevailing markup phase, reinforcing the stock’s position as a leading short-term outperformer.

📊 𝗪𝗘𝗘𝗞𝗟𝗬 𝗪𝗔𝗧𝗖𝗛𝗟𝗜𝗦𝗧: 𝗦𝗧𝗢𝗖𝗞 𝗧𝗥𝗔𝗗𝗜𝗡𝗚 𝗢𝗣𝗣𝗢𝗥𝗧𝗨𝗡𝗜𝗧𝗜𝗘𝗦𝗙𝗼𝗿 𝘁𝗵𝗲 𝗪𝗲𝗲𝗸 𝗕𝗲𝗴𝗶𝗻𝗻𝗶𝗻𝗴 𝗠𝗮𝘆 𝟰, 𝟮𝟬𝟮𝟲The following stocks are positioned for...
03/05/2026

📊 𝗪𝗘𝗘𝗞𝗟𝗬 𝗪𝗔𝗧𝗖𝗛𝗟𝗜𝗦𝗧: 𝗦𝗧𝗢𝗖𝗞 𝗧𝗥𝗔𝗗𝗜𝗡𝗚 𝗢𝗣𝗣𝗢𝗥𝗧𝗨𝗡𝗜𝗧𝗜𝗘𝗦
𝗙𝗼𝗿 𝘁𝗵𝗲 𝗪𝗲𝗲𝗸 𝗕𝗲𝗴𝗶𝗻𝗻𝗶𝗻𝗴 𝗠𝗮𝘆 𝟰, 𝟮𝟬𝟮𝟲

The following stocks are positioned for potential upside this week, supported by strong technical structures, improving momentum, and favorable earnings sentiment:

1️⃣ 𝗠𝗧𝗡 𝗡𝗶𝗴𝗲𝗿𝗶𝗮 (10% – 15% Upside Potential)
MTN Nigeria Communications Plc remains on our watchlist following a decisive technical breakout supported by exceptionally strong Q1 2026 earnings momentum. The combination of 41.6% revenue growth, significant EPS expansion, robust operating cash flows, and sustained institutional buying activity suggests continued upside potential. Price action remains firmly within a bullish markup phase, with momentum indicators and volume structure supporting further appreciation. We see scope for an additional 10%–15% upside over the near term as market participants continue to reprice the stock in line with its improving fundamentals and strengthened balance sheet.

2️⃣ 𝗗𝗔𝗡𝗚𝗖𝗘𝗠 (7% – 10% Upside Potential)
Dangote Cement Plc remains on our strategic watchlist following a strong Q1 2026 earnings release that reinforced the company’s position as a leading industrial growth play. The 53.5% year-on-year increase in profit after tax to N321.1 billion, alongside robust revenue growth of 20.4% and expanding EBITDA margins, reflects improving operational leverage, pricing strength, and continued efficiency gains. Supported by higher production volumes and growing export pe*******on, the stock continues to exhibit favorable momentum characteristics. We see potential for a 7%–10% upside over the week as institutional interest and earnings-driven repricing momentum continue to strengthen market sentiment around the stock.

3️⃣ 𝗦𝗧𝗔𝗡𝗕𝗜𝗖 𝗜𝗕𝗧𝗖 (7% – 10% Upside Potential)
Stanbic IBTC Holdings Plc remains on our tactical watchlist for the week as the stock continues to exhibit strong institutional momentum following its sustained multi-month breakout structure. Price action remains firmly above key moving averages, while volume dynamics continue to support bullish continuation despite recent volatility. The broader trend structure suggests underlying demand remains intact, with momentum traders and institutional participation still active within the current markup phase. We see potential for an additional 7%–10% upside over the week as the market continues to respond positively to the stock’s strong technical positioning and sustained buying interest.

⚠️ 𝗗𝗶𝘀𝗰𝗹𝗮𝗶𝗺𝗲𝗿: This content is provided for informational purposes only and should not be considered financial advice. Always conduct your own analysis and risk assessment before making investment decisions.

📊 𝗪𝗘𝗘𝗞𝗟𝗬 𝗪𝗔𝗧𝗖𝗛𝗟𝗜𝗦𝗧 𝗥𝗘𝗩𝗜𝗘𝗪 – 𝗪𝗘𝗘𝗞 𝗘𝗡𝗗𝗘𝗗 𝟮𝟰 𝗔𝗣𝗥𝗜𝗟 𝟮𝟬𝟮𝟲The week delivered a strong bullish outing for most names on the wat...
25/04/2026

📊 𝗪𝗘𝗘𝗞𝗟𝗬 𝗪𝗔𝗧𝗖𝗛𝗟𝗜𝗦𝗧 𝗥𝗘𝗩𝗜𝗘𝗪 – 𝗪𝗘𝗘𝗞 𝗘𝗡𝗗𝗘𝗗 𝟮𝟰 𝗔𝗣𝗥𝗜𝗟 𝟮𝟬𝟮𝟲

The week delivered a strong bullish outing for most names on the watchlist, with several counters hitting or exceeding projected upside targets 👇

𝗨𝗡𝗜𝗢𝗡𝗗𝗜𝗖𝗢𝗡
Led the pack with an impressive 30.00% gain, closing the week at ₦21.90 from ₦16.85.
➡️ A strong momentum-driven rally, outperforming projected expectations.

𝗙𝗶𝗱𝗲𝗹𝗶𝘁𝘆 𝗕𝗮𝗻𝗸
Posted an 11.22% gain, closing at ₦22.30 from ₦20.05.
➡️ Strong follow-through and exceeded projected range.

𝗨𝗕𝗔
Advanced 14.58% to close at ₦55.00 from ₦48.00.
➡️ Maintained strong institutional momentum and continued price discovery.

𝗙𝗶𝗿𝘀𝘁𝗛𝗼𝗹𝗱𝗖𝗼
Recorded a 17.19% gain, closing the week at ₦75.00 from ₦64.00.
The stock touched a weekly high of ₦77.00, representing a 20.31% increase, before settling lower at the close.
➡️ Strong rally with mild profit-taking towards week-end.

𝗙𝗖𝗠𝗕
Closed the week at ₦12.65, up 4.98% from ₦12.05.
The stock, however, touched a weekly high of ₦13.50, reflecting a 12.03% gain before retracing.
➡️ Momentum weakened towards the close as profit-taking set in.

𝗧𝗿𝗮𝗻𝘀𝗰𝗼𝗿𝗽
Bucked the positive trend, declining to ₦47.10 from ₦48.20, a 2.28% loss for the week.
The stock had earlier rallied to a weekly high of ₦49.80 (+3.32%) before reversing.
➡️ Weak close after failing to sustain early-week momentum.

📌 𝗢𝘃𝗲𝗿𝗮𝗹𝗹 𝗜𝗻𝘀𝗶𝗴𝗵𝘁
The watchlist delivered a largely successful performance, with 5 out of 6 stocks posting gains, and several surpassing expectations. Banking stocks remained the major drivers of the rally, confirming continued liquidity inflow into the sector.

However, signs of profit-taking emerged in some counters such as FCMB and Transcorp towards the close of the week.

The key lesson remains:
➡️ Early entry into momentum stocks matters, while discipline in taking profit protects gains.

Let’s prepare for another trading week 📈

𝗙𝗘𝗕𝗥𝗨𝗔𝗥𝗬 𝟮𝟬𝟮𝟲: 𝗗𝗜𝗦𝗜𝗡𝗙𝗟𝗔𝗧𝗜𝗢𝗡 𝗦𝗟𝗢𝗪𝗦 𝗔𝗦 𝗠𝗢𝗠𝗘𝗡𝗧𝗨𝗠 𝗥𝗘𝗩𝗘𝗥𝗦𝗘𝗦Nigeria’s headline inflation edged lower to 15.06% YoY in February...
18/03/2026

𝗙𝗘𝗕𝗥𝗨𝗔𝗥𝗬 𝟮𝟬𝟮𝟲: 𝗗𝗜𝗦𝗜𝗡𝗙𝗟𝗔𝗧𝗜𝗢𝗡 𝗦𝗟𝗢𝗪𝗦 𝗔𝗦 𝗠𝗢𝗠𝗘𝗡𝗧𝗨𝗠 𝗥𝗘𝗩𝗘𝗥𝗦𝗘𝗦

Nigeria’s headline inflation edged lower to 15.06% YoY in February 2026, from 15.10% in January, sustaining the disinflation trend. However, the underlying momentum weakened significantly as monthly inflation rebounded sharply to 2.01%, reversing the -2.88% contraction recorded in January.

This shift is critical. While the marginal decline in YoY inflation suggests continued base-effect moderation, the positive MoM print signals a renewed increase in price levels, indicating that inflationary pressures are re-emerging in the near term.

Core inflation moderated further to 15.88% YoY, down from 17.72% in January, while core MoM rose to 0.89% from -1.69%. This suggests that although underlying inflation remains on a downward annual trajectory, cost pressures across non-food segments are beginning to rebuild on a monthly basis.

Food inflation was the primary driver of this reversal. Food inflation accelerated to 12.12% YoY, up from 8.89%, while monthly food inflation surged to 4.69%, reversing the sharp -6.02% decline recorded in January. This indicates a renewed uptick in food prices, likely reflecting seasonal adjustments, supply disruptions, and persistent structural inefficiencies within the food value chain.

Overall, February data highlights a transition from broad-based disinflation to a more fragile and uneven inflation path, where short-term price pressures are reasserting themselves despite favorable base effects.

𝗜𝗺𝗽𝗹𝗶𝗰𝗮𝘁𝗶𝗼𝗻𝘀 𝗳𝗼𝗿 𝗶𝗻𝘃𝗲𝘀𝘁𝗼𝗿𝘀 𝗮𝗻𝗱 𝗰𝗮𝗽𝗶𝘁𝗮𝗹 𝗮𝗹𝗹𝗼𝗰𝗮𝘁𝗶𝗼𝗻

The February inflation dynamics introduce a more nuanced investment environment.

For fixed income investors, the rebound in MoM inflation suggests that the recent expansion in real yields may face short-term pressure if price increases persist. While the YoY disinflation trend still supports real return improvement, investors may need to adopt a more tactical duration strategy, focusing on segments of the curve that balance yield optimization with inflation risk.

In equities, the resurgence in food and headline inflation introduces margin risks, particularly for consumer goods and manufacturing firms exposed to input cost volatility. However, sectors with pricing power and strong cost pass-through mechanisms are better positioned to navigate this phase.

From a monetary policy standpoint, the data complicates the outlook. While declining YoY inflation supports the argument for eventual policy easing, the reacceleration in monthly inflation is likely to reinforce a cautious stance. Policymakers may prioritize inflation stability over early easing, especially given the sensitivity of food prices and exchange rate dynamics.

Looking ahead, the inflation environment is no longer decisively disinflationary but transitional, requiring a shift from broad optimism to selective and data-driven positioning. Investors should remain attentive to short-term inflation signals, particularly in food prices, while positioning strategically for medium-term disinflation once current pressures stabilize……Read More

https://surl.lu/uioonb







𝗠𝗣𝗖 𝗖𝘂𝘁𝘀 𝗠𝗣𝗥 𝗯𝘆 𝟱𝟬𝗯𝗽𝘀 𝘁𝗼 𝟮𝟲.𝟱% 𝗳𝗿𝗼𝗺 𝟮𝟳.𝟬%At its 304th meeting, the Monetary Policy Committee reduced the Monetary Policy...
25/02/2026

𝗠𝗣𝗖 𝗖𝘂𝘁𝘀 𝗠𝗣𝗥 𝗯𝘆 𝟱𝟬𝗯𝗽𝘀 𝘁𝗼 𝟮𝟲.𝟱% 𝗳𝗿𝗼𝗺 𝟮𝟳.𝟬%

At its 304th meeting, the Monetary Policy Committee reduced the Monetary Policy Rate by 50 basis points to 26.5% from 27.0%, aligning precisely with my December 2025 projection issued alongside the November inflation report, where I anticipated a calibrated adjustment as the initial step toward policy normalization (https://surl.li/uwmzwj).

𝗖𝗮𝘀𝗵 𝗥𝗲𝘀𝗲𝗿𝘃𝗲 𝗥𝗮𝘁𝗶𝗼 (𝗖𝗥𝗥): Retained at 45% for Commercial Banks and 16% for Merchant Banks; the 75% CRR on Non-TSA public sector deposits was also maintained.

𝗦𝘁𝗮𝗻𝗱𝗶𝗻𝗴 𝗙𝗮𝗰𝗶𝗹𝗶𝘁𝗶𝗲𝘀 𝗖𝗼𝗿𝗿𝗶𝗱𝗼𝗿: Maintained at +50 / –450 basis points around the MPR.






21/02/2026

The Access Bank Lagos City Marathon 2026 was more than a race for me, it was strategy in motion.

In investing and in life, results are not accidental.
💫 You assess risk.
💫You prepare deliberately.
💫 You manage your pace.
💫You stay disciplined under pressure.
💫 And you finish strong.

While others slowed down, consistency carried me forward.
No stopping. No shortcuts. Just controlled ex*****on.

Performance compounds.
Discipline pays dividends.

This medal is not just a reward for speed, it is proof that sustainable strategy always wins.

Still building. Still running. Still compounding.

𝗝𝗔𝗡𝗨𝗔𝗥𝗬 𝟮𝟬𝟮𝟲: 𝗡𝗜𝗚𝗘𝗥𝗜𝗔’𝗦 𝗜𝗡𝗙𝗟𝗔𝗧𝗜𝗢𝗡 𝗠𝗢𝗠𝗘𝗡𝗧𝗨𝗠 𝗧𝗨𝗥𝗡𝗦 𝗗𝗘𝗖𝗜𝗦𝗜𝗩𝗘𝗟𝗬 𝗗𝗢𝗪𝗡𝗪𝗔𝗥𝗗Nigeria’s headline inflation eased to 15.10% YoY in ...
17/02/2026

𝗝𝗔𝗡𝗨𝗔𝗥𝗬 𝟮𝟬𝟮𝟲: 𝗡𝗜𝗚𝗘𝗥𝗜𝗔’𝗦 𝗜𝗡𝗙𝗟𝗔𝗧𝗜𝗢𝗡 𝗠𝗢𝗠𝗘𝗡𝗧𝗨𝗠 𝗧𝗨𝗥𝗡𝗦 𝗗𝗘𝗖𝗜𝗦𝗜𝗩𝗘𝗟𝗬 𝗗𝗢𝗪𝗡𝗪𝗔𝗥𝗗

Nigeria’s headline inflation eased to 15.10% YoY in January 2026, marginally lower than 15.15% in December 2025, extending the disinflation trend into the new year. More importantly, monthly headline inflation contracted by 2.88%, reversing the 0.54% MoM increase recorded in December. This indicates not just slower inflation, but an outright decline in price levels on a month-to-month basis.

While year-on-year figures are partly influenced by base effects, the negative MoM print provides stronger evidence of easing underlying price pressures, signalling a clear shift in inflation momentum.

Core inflation moderated to 17.72% YoY, down from 18.63% in December, while core prices declined by 1.69% MoM, compared to a prior increase of 0.58%. This suggests reduced cost-push pressures across non-food sectors, reflecting improving macro stability and softer demand conditions.

Food inflation recorded the sharpest adjustment. Food inflation eased to 8.89% YoY, down from 10.84%, while monthly food inflation contracted by 6.02%, compared to a mild decline of 0.36% in December. This points to easing supply constraints, improved food availability, and reduced seasonal pressures.

𝗜𝗺𝗽𝗹𝗶𝗰𝗮𝘁𝗶𝗼𝗻𝘀 𝗳𝗼𝗿 𝗶𝗻𝘃𝗲𝘀𝘁𝗼𝗿𝘀 𝗮𝗻𝗱 𝗰𝗮𝗽𝗶𝘁𝗮𝗹 𝗮𝗹𝗹𝗼𝗰𝗮𝘁𝗶𝗼𝗻

For investors, the implications are material. Sustained disinflation improves real returns on fixed-income instruments, particularly at the short and mid-tenor end of the curve, where yields remain elevated relative to inflation. As inflation expectations moderate, real yields expand, strengthening the attractiveness of government securities and high-quality credit exposures.

Equities also stand to benefit indirectly. Lower inflation reduces pressure on input costs and supports margin stabilization, particularly for consumer-facing and manufacturing firms. If disinflation persists, it creates room for valuation re-rating, as the discount rate applied to future cash flows begins to ease.

From a policy perspective, the inflation trajectory strengthens the case for a cautious pivot in monetary policy over the coming months. While policymakers are likely to remain sensitive to exchange-rate dynamics and residual food supply risks, the combination of declining headline, core, and food inflation provides policy space for gradual normalization, rather than prolonged monetary tightness.

Looking ahead, the macro environment is becoming more supportive of measured risk-taking rather than defensive positioning. Capital preservation remains critical, but the improving inflation outlook increases the scope for selective duration extension, equity exposure in fundamentally strong sectors, and strategic positioning ahead of an eventual easing cycle.

https://surl.li/vyzlwz







𝗡𝗶𝗴𝗲𝗿𝗶𝗮’𝘀 𝗧𝗮𝘅 𝗟𝗮𝘄 𝗗𝗲𝗯𝗮𝘁𝗲 (𝟯): 𝗞𝗣𝗠𝗚 𝗼𝗻 𝗡𝗼𝗻-𝗥𝗲𝘀𝗶𝗱𝗲𝗻𝘁 𝗧𝗮𝘅𝗮𝘁𝗶𝗼𝗻; 𝗖𝗹𝗮𝗿𝗶𝘁𝘆, 𝗡𝗼𝘁 𝗖𝗼𝗻𝗳𝘂𝘀𝗶𝗼𝗻As part of my ongoing review of KPMG ...
15/01/2026

𝗡𝗶𝗴𝗲𝗿𝗶𝗮’𝘀 𝗧𝗮𝘅 𝗟𝗮𝘄 𝗗𝗲𝗯𝗮𝘁𝗲 (𝟯): 𝗞𝗣𝗠𝗚 𝗼𝗻 𝗡𝗼𝗻-𝗥𝗲𝘀𝗶𝗱𝗲𝗻𝘁 𝗧𝗮𝘅𝗮𝘁𝗶𝗼𝗻; 𝗖𝗹𝗮𝗿𝗶𝘁𝘆, 𝗡𝗼𝘁 𝗖𝗼𝗻𝗳𝘂𝘀𝗶𝗼𝗻

As part of my ongoing review of KPMG Nigeria’s commentary on the New Tax Act, I turn to their observations on Section 17(3)(b) and 17(4) of the Nigeria Tax Act and Sections 6(1) and 11(3) of the Nigeria Tax Administration Act, dealing with the taxation of non-resident companies.

KPMG argues that although the law makes withholding tax the final tax for non-residents without a Permanent Establishment (PE) or Significant Economic Presence (SEP), the law does not clearly exempt them from tax registration, creating what they describe as a “gap”.

Let us look at what the law actually does.

𝗪𝗵𝗮𝘁 𝘁𝗵𝗲 𝗹𝗮𝘄 𝗮𝗹𝗿𝗲𝗮𝗱𝘆 𝗽𝗿𝗼𝘃𝗶𝗱𝗲𝘀
Section 17(4) of the NTA states that where a Nigerian resident pays a non-resident that has no PE or SEP in Nigeria, the withholding tax deducted at source is final.

In tax law, “final” means:
💫 No further tax assessment
💫 No profit computation
💫 No additional tax liability
💫 No tax returns

The tax obligation ends at the point of deduction.

Section 11(3) of the NTAA then removes any remaining doubt. It provides that a non-resident whose only Nigerian income has been subject to tax deducted at source is not required to file tax returns.

So the law already says two very clear things:
💫 The tax is final
💫 No return is required
That is exactly how final withholding regimes work in modern tax systems.

𝗪𝗵𝗮𝘁 𝗮𝗯𝗼𝘂𝘁 𝘁𝗮𝘅 𝗿𝗲𝗴𝗶𝘀𝘁𝗿𝗮𝘁𝗶𝗼𝗻 𝘂𝗻𝗱𝗲𝗿 𝗦𝗲𝗰𝘁𝗶𝗼𝗻 𝟲(𝟭)?

KPMG’s concern is that Section 6(1) lists persons required to register for tax and does not expressly exclude these non-residents.

But this is where legal interpretation matters.

You do not register for a tax system when:
💫You are not assessable
💫You do not file returns
💫You owe no further tax

Registration exists only to support assessment, filing and collection.

Once the law has removed all three, registration collapses automatically.

In law, this is called harmonious interpretation. Sections 6(1), 11(3) and 17(4) must be read together. When read together, the result is clear:

If a non-resident has no PE or SEP in Nigeria and its Nigerian income is fully taxed by withholding, that non-resident is outside Nigeria’s tax compliance system.

This tax system is fully aligned with global best practice.

𝗪𝗵𝗮𝘁 𝗞𝗣𝗠𝗚 𝗵𝗮𝘀 𝗿𝗲𝗮𝗹𝗹𝘆 𝗶𝗱𝗲𝗻𝘁𝗶𝗳𝗶𝗲𝗱
This is not a tax policy error.
It is not a loophole.
It is not a loss of Nigeria’s taxing rights.

At most, KPMG has identified a drafting clarity point: they want Section 6(1) to restate what Sections 17(4) and 11(3) already achieve.

But in substance, the law is already correct.

Nigeria is simply saying:
If you do not have a real economic presence here, we will tax you at source and let you go.

That protects Nigeria’s tax base without discouraging cross-border trade and investment.


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