Notably, non-resident companies (NRCs) are now required to deduct WHT, though it remains unclear whether this applies to NRCs without a fixed base or dependent agency in Nigeria.
Additionally, the Circular raises concerns about applying WHT to barter or exchange transactions, where both parties simultaneously give and receive value. It remains uncertain if both parties should deduct WHT based on the fair market value of exchanged goods or services.
Furthermore, the Circular specifies that WHT exemptions will not apply to fees or commissions retained upfront by unlicensed agents, despite the Regulations not mentioning a licensing requirement.
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