By Ola Daramola
AS of January 1, 2026, Nigeria’s most ambitious tax reform in decades moved from theory to execution. New laws are live, a restructured tax authority is operational, and the rules governing how money moves into, out of and within the country have fundamentally changed.
For businesses facilitating cross-border payments, this is no longer a policy discussion. It is the system within which every transaction now operates.
Every service fee, FX conversion, digital charge, and foreign currency balance is increasingly treated as a potential tax event, not hypothetically, but operationally.
This marks a decisive shift in how cross-border payments must be designed, priced and executed in Nigeria. The question for payment firms, fintech platforms and financial institutions is no longer what the new tax laws say, but how to operate competitively inside this framework without losing speed, margin or trust.
In 2026, cross-border payments are no longer defined by velocity alone. They are defined by correctness. Tax authorities now operate with greater automation, real-time visibility and system-level integration. Outcomes are increasingly embedded into transaction flows rather than resolved after the fact. Group structures, non-resident arrangements, and foreign currency positions are more visible than ever, forcing firms to confront compliance as an operational state rather than a periodic obligation.
VAT now applies more clearly to digital services, bundled platforms and transaction fees, directly influencing pricing and customer communication. Withholding tax considerations are reshaping treasury strategies, while inter company arrangements face deeper scrutiny under minimum tax and controlled foreign company rules.
When compliance breaks down in this environment, the symptoms are no longer
missed filings; they appear as mispriced products, unexplained deductions, settlement delays and persistent reconciliation issues.
The pressure points across the ecosystem are already evident. Pricing is the first fault line. Firms that have not embedded tax logic directly into their pricing models are quietly absorbing margin erosion, particularly in high-volume, low-margin corridors where small discrepancies compound quickly. Settlement is another.
When tax handling is unclear or inconsistent, reconciliation slows, not because funds cannot move, but because teams are resolving mismatches after transactions have closed.
Customer experience is increasingly affected.
Users may not understand VAT mechanics or withholding rules, but they immediately notice unexplained fees or shifting costs. In cross-border payments, trust is fragile. Once lost, it is difficult to regain.
Internally, many organisations are also experiencing tension. Product teams push for speed, finance teams prioritise accuracy, and tax teams intervene after systems are already live. In 2026, these silos are no longer inefficient; they are risky. Certain truths now define whether a cross-border payments business is viable in Nigeria. Tax can no longer be handled after the transaction; VAT and withholding obligations must be addressed at the point of exchange. Treasury strategy must be tax-aware; holding foreign currency purely for convenience, without understanding its tax implications, is no longer defensible.
Intercompany routing must reflect operational reality rather than paper structure, and compliance must be predictable. Regulators and partners are less tolerant of improvisation. Consistency now matters more than cleverness.
These are not best practices; they are baseline requirements for operating in 2026. Firms operating effectively under the new framework do not feel burdened by tax. Instead, tax is quietly embedded into how the business works. Payment flows are designed so VAT on digital services is applied clearly and consistently.
Pricing models account for indirect taxes upfront, allowing firms to compete transparently rather than reactively. Treasury teams manage foreign currency positions with tax outcomes in mind, alongside liquidity and yield. Intercompany agreements align with operational reality, and technology supports compliance rather than complicating it, reducing manual intervention and error.
From the outside, customers see clarity and regulators see consistency. Internally, teams spend less time firefighting and more time building. The strategic question facing cross-border payment leaders in 2026 is not whether the tax framework is convenient or ideal. It is whether their businesses are designed to operate smoothly within it. Cross-border payments will continue to grow, digital services will continue to scale and Nigeria will remain a critical market.
The firms that succeed will be those that treat the 2026 tax reset as the new ground rules and design accordingly, rather than attempting to work around it. This is now the operating norm.
The only remaining decision is how deliberately businesses choose to align with it.
Daramola is the Group Chief Executive Officer, BlueBulb. He wrote from Lagos.
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