International Tax Treaties and Foreign Investment Facilitation in Nigeria

This study evaluates the role of Nigeria's network of double taxation agreements (DTAs) in facilitating foreign direct investment and preventing cross-border tax conflicts. Nigeria has concluded DTAs with a range of countries including the United Kingdom, France, China, South Africa, and several other treaty partners, yet the actual utilisation of treaty benefits by foreign investors and the capacity of the FIRS to administer treaty provisions remain understudied. Using a professional applied research design, the study reviews the texts of Nigeria's ten most economically significant DTAs, analyses treaty utilisation statistics from the FIRS international tax division, and conducts structured interviews with eight international tax consultants advising multinationals with Nigerian operations. Comparative case studies of treaty administration in Ghana, Rwanda, and Mauritius provide additional benchmarks. Descriptive analysis, treaty provision comparison tables, and thematic coding of interview data are employed. The study expects to find that treaty benefits are underutilised due to limited FIRS capacity to process treaty-based withholding tax relief claims efficiently and to taxpayer unfamiliarity with treaty entitlements. Recommendations include creating a publicly accessible treaty benefit application portal, publishing simplified treaty summaries for each active DTA, strengthening the FIRS international tax unit with specialist treaty administration training, and accelerating treaty negotiations with emerging investor-origin countries. Keywords: double taxation agreements, foreign direct investment, FIRS, international tax, treaty benefits.