NRS crypto rules could lead to multiple taxes — PwC

By Abubakar Yunus

The PricewaterhouseCoopers (PwC) said the Nigeria Revenue Service (NRS) guidelines on virtual assets could subject cryptocurrency transactions to multiple taxes, including income tax, withholding tax (WHT), value-added tax (VAT) and stamp duty.

PwC disclosed in its August 2026 tax alert titled ‘Taxing the Intangible: A Critical Analysis of the NRS Guidelines on Taxation of Virtual Assets,’ following the publication of the NRS guidelines on July 31.

The professional services firm said “a single VA transaction may give rise to multiple tax liabilities based on triggers called ‘taxable events’”.

According to the firm, income tax applies to gains from the disposal of virtual assets as well as income or gifts received in virtual assets, including employment income, professional fees, mining rewards, staking rewards, decentralised finance (DeFi) rewards and airdrops.

PwC said the guidelines also introduce a 1 percent WHT on gross disposal proceeds for cryptocurrencies, security and investment tokens and non-fungible tokens (NFTs).

“Passive income from staking, mining, airdrops, and DeFi yield attracts WHT at 10%,” the company said.

The firm said VAT at 7.5 percent would apply to services connected with virtual asset transactions, including exchange fees, brokerage commissions, custody fees and advisory services.

PwC also said the guidelines impose a 1.5 percent stamp duty on token-to-fiat and fiat-to-token transfers, with the tax to be borne by the transferee.

However, according to the report NRS’ approach to calculating gains in dollar terms is “a welcome and pragmatic policy choice”.

The firm said the method would prevent taxpayers from being taxed on “phantom gains” arising solely from naira depreciation.

“Under this approach, the gain is computed by reference to the USD value of the asset at acquisition and at disposal; only the resulting dollar gain is then converted to Naira at the CBN/NAFEM rate on the disposal date,” the company said.

PwC said the guidelines also provide safe harbours for certain transactions, noting that merely holding a virtual asset does not trigger taxation.

The report said transfers between wallets owned by the same individual, staking lock-ups, minting of NFTs, collateralised loans, wrapping and unwrapping of tokens and deposits into DeFi protocols in exchange for receipt tokens are treated as non-taxable events.

PwC said virtual asset service providers (VASPs) would play a central role in tax collection under the new framework.

“VASPs must withhold WHT on disposals, deduct stamp duty in token units, enforce Tax ID requirements as a precondition for account activation, and file comprehensive returns,” the company said.

The firm added that non-compliance by VASPs or peer-to-peer marketplaces would attract a penalty of N10 million for the first month and N1 million for each subsequent month of default.

PwC also raised concerns over the absence of an effective date for the guidelines, saying they introduce obligations that are not contained in the Nigeria Tax Act (NTA) or Nigeria Tax Administration Act (NTAA).

“The publication date of the Guidelines is 31 July 2026 and does not include any effective date even though it introduces some new obligations that are not in the Nigeria Tax Act (NTA) or Nigeria Tax Administration Act (NTAA),” the company said.

PwC advised taxpayers involved in virtual asset activities to register for tax and obtain a Tax ID, while urging VASPs to review their systems to ensure they can comply with the new tax requirements.