Automatic Exchange of Financial Information, Offshore Evasion, and Revenue Implications for Nigeria

This doctoral study examines the revenue implications for Nigeria of international automatic exchange of financial information frameworks, particularly the OECD Common Reporting Standard and the Foreign Account Tax Compliance Act, in recovering offshore tax-evaded wealth held by Nigerian residents. Nigeria has long been identified as a significant source of illicit offshore financial wealth, yet the revenue authority has had limited practical capacity to identify, assess, and collect taxes on offshore income and assets. Participation in CRS and FATCA information exchange represents a structural shift in the information environment available to the FIRS. The study develops a micro-founded offshore evasion model in which Nigerian high-net-worth individuals choose between onshore and offshore asset holding based on detection risk, expected penalties, and the quality of domestic property rights institutions. The model generates testable predictions about the asset repatriation response to CRS implementation, estimated using a difference-in-differences strategy comparing Nigerian resident deposits in CRS-early-adopting and CRS-late-adopting offshore financial centres before and after implementation. Complementary analysis of FIRS voluntary disclosure programme data and Nigerian Suspicious Transaction Report filings provides corroborating evidence. The study expects to find economically significant deposits in offshore centres with which Nigeria has activated CRS reciprocal exchange agreements and a measurable repatriation response concentrated among deposits in lower-secrecy jurisdictions. Theoretical contributions include the domestic institutions-offshore evasion substitution model. Keywords: automatic exchange of information, Common Reporting Standard, offshore evasion, Nigeria, capital flight.