Nigeria Tax Administration Act, 2025 · Circular 2026/21 ¶5
The six categories, and why yours matters
What you hold decides whether tax is withheld at source and how the gain is measured.
Who this lands on: Everyone holding or transacting in virtual assets.
Category 1 — cryptocurrencies and exchange tokens (Bitcoin, Ether, Solana, BNB). Income tax on gains at disposal, plus stamp duty on eligible transfers.
Category 2 — stablecoins and payment tokens (USDT, USDC, DAI). The gain is measured against the fiat currency the coin tracks, so it is usually nil or tiny. No withholding tax on disposal; anything that does arise goes on the self-assessment return. Where a stablecoin pays a yield, that yield is assessed as Category 4.
Category 3 — security and investment tokens: tokenised equity, bonds, revenue-sharing and asset-backed tokens. Gains and stamp duty as for Category 1. The stocks-and-shares exemption in s.184(h) of the Tax Act only reaches tokenised Nigerian stocks and shares, not the whole category.
Category 4 — utility and governance tokens, including anything paying staking rewards, DeFi yield or liquidity rewards. Those rewards are income on the day you receive them.
Category 5 — NFTs. How they are taxed follows what you actually are: a creator selling their own work has business income; an investor reselling has a gain.
Category 6 — sovereign digital currency (eNaira, foreign CBDCs). Treated as ordinary money. No virtual-asset obligations arise.