PwC Nigeria has identified several areas of ambiguity in the Nigeria Revenue Service’s newly issued Guidelines on the Taxation of Virtual Assets, even as it urged tax payers to brace for the implementation.

The firm, in a tax alert titled Taxing the intangible: A critical analysis of the NRS guidelines on taxation of virtual assets, said the guidelines provide greater clarity on the tax treatment of digital assets but leave several practical and legal questions unresolved.

The Nigeria Revenue Service, formerly the Federal Inland Revenue Service, published Information Circular No. 2026/21, titled “Guidelines on the Taxation of Virtual Assets”, on July 31, 2026.

The guidelines represent the first comprehensive administrative framework for taxing virtual assets in Nigeria.

One of the ambiguities identified by PwC concerns the safe harbour for transfers between wallets owned by the same person.

The guidelines provide that transfers between wallets owned by the same individual do not constitute a taxable disposal.

However, PwC noted that the safe harbour applies only to individuals and does not extend to companies or partnerships.

According to the professional services firm, this could create difficulties for corporate treasury operations involving multiple wallets, particularly where companies move virtual assets between wallets they own.

PwC also questioned the requirement for virtual asset prices to be obtained from an “aggregator approved by the Service”.

The firm noted that the requirement creates a dependency on a list of approved aggregators that has not yet been published.

The absence of the list could create uncertainty for taxpayers and Virtual Asset Service Providers (VASPs) that need to determine the appropriate valuation of assets for tax computation and reporting purposes.

Another issue flagged by PwC is the interaction between the one per cent withholding tax imposed on gross disposal proceeds and income tax calculated on net gains.

Under the guidelines, VASPs are required to withhold one per cent of gross disposal proceeds for certain categories of virtual assets, while income tax is also applicable to gains from disposal.

“The interaction between the WHT on gross proceeds and the income tax on net gains will require careful reconciliation on annual returns to avoid over-taxation,” PwC stated.

Under the guidelines, VASPs are expected to withhold tax on disposals, collect stamp duty, enforce Tax ID requirements before account activation, file returns and maintain records.

The penalty regime includes a N10 million penalty for the first month of non compliance and N1 million for each subsequent month.

PwC questioned whether it is fair to impose these obligations on VASPs when similar responsibilities are not imposed on bureaux de change and stock exchanges.

It also questioned whether the NRS has the authority to impose withholding tax obligations outside the Withholding Tax Regulations 2024.

The new guidelines on the taxation of virtual assets have triggered debate among cryptocurrency investors, traders and industry stakeholders, with some warning that excessive taxation could discourage innovation, while others welcome the clarity provided by the framework.

Some users also questioned whether airdrops should be subject to taxation, while others argued that the guidelines provide greater clarity on how existing tax obligations apply to digital assets.

The guidelines came weeks after President Bola Tinubu signed the Presidential Executive Order on Virtual Assets Coordination, 2026, establishing a coordinated regulatory framework for cryptocurrencies, stablecoins, tokenised assets and other digital financial products.

Meanwhile, a group of stakeholders in the digital asset ecosystem, Digital Assets Coalition, has warned that Nigeria’s virtual asset economy, currently valued at $92 billion, could face reduced investment and slower expansion because of the new tax rules.

According to the group, the tax structure could have unintended consequences for a sector that has become an important channel for global payments, remittances, savings and income generation, especially among young Nigerians.

The Coalition, an alliance representing digital asset participants and operators in Nigeria, said the country’s virtual asset market, currently the largest in Sub-Saharan Africa, has grown into a significant part of the emerging digital economy and should be protected from policies that could limit investment and economic activity.