International Peer-Reviewed Journal•Open Access•ISSN 2456-8880
irejournals@gmail.com•+91-7433024337

Home / Current Issue / Paper 1710538

1710538 Vol 9 · Issue 3 Download Paper

Taxation of Digital Services in a Globalized Economy: Implications for Nigeria and Africa

Uzor Chijioke Esq.

Subject area: Arts, Social Sciences and Humanities  ·  Area of research: Law

DOI: 10.64388/IREV9I3-1710538-079

Abstract

The pace of digitalization of the world's economy has exposed the flaw of traditional international tax systems, particularly digital services. Multinational technology companies more and more make huge revenues across borders without physical presence, which creates severe challenges for states to exert taxing powers. This paper critically examines taxation of digital services in a global economy, notably Nigeria and Africa. Based on comparative and doctrinal analysis, the study canvasses international tax principles, OECD/G20 Inclusive Framework proposals, United Nations negotiations, and African national tax reforms. Evidence highlights that while unilateral measures such as Digital Services Taxes (DSTs) and Significant Economic Presence (SEP) regulations are lucrative in terms of short-term budgetary gains, they may also carry the risk of administrative inefficiency, double taxation, and potential disagreement in trade. Nigeria's new reforms, including the VAT imposition on non-resident digital providers and SEP actions, are important policy developments that are in the course of implementation but are hampered by the shortcoming of weak administrative capacity and deficit in compliance. Across Africa, similar experiences demonstrate a delicate balance between generating revenue and promoting digital innovation. Tenuously structured levies, such as mobile money, have in some cases jettisoned financial inclusion, demonstrating the risk of unilateral dependence. The report explains that solutions in the long term lie in enhancing domestic enforcement capacity, cooperating more robustly at the regional level through bodies like ECOWAS and the African Union, and engaging more intensively in multilateral tax talks. Lastly, the article argues that a balanced strategy?based on VAT reforms, collection at the platform level, harmonization of regional policy, and positive participation in global arrangements?has the best potential avenue for African countries. These initiatives can bring more equitable revenue sharing, protect digital inclusion, and more seamlessly integrate Africa into the new international tax architecture.

Keywords

Digital Services Tax, Globalization, International Taxation, Africa, OECD

References

[1] Adegoke, Y. (2021). Tax dispute resolution in Nigeria: The role of the Tax Appeal Tribunal. African Journal of International and Comparative Law, 29(3), 387–406. https://doi.org/10.3366/ajicl.2021.0367

[2] Akinyemi, B. (2022). Nigeria and the OECD’s two-pillar solution: An African perspective on digital taxation. Journal of International Economic Law, 25(2), 255–277. https://doi.org/10.1093/jiel/jgac012

[3] Akindayomi, A., & Oladipupo, O. (2023). Taxing the digital economy: Nigeria’s approach in the global tax reform era. International Journal of Law and Management, 65(4), 472–490. https://doi.org/10.1108/IJLMA-03-2023-0057

[4] Asongu, S. A., & Odhiambo, N. M. (2021). Enhancing ICT for tax revenue mobilization in sub-Saharan Africa. Telecommunications Policy, 45(5), 102–117. https://doi.org/10.1016/j.telpol.2021.102117

[5] Avi-Yonah, R. S., & Xu, H. (2020). Evaluating the OECD’s proposals for taxing the digital economy. Intertax, 48(2), 123–134.

[6] Brauner, Y., & Pistone, P. (2021). Adapting current international taxation to new business models: Two proposals for the European Union. World Tax Journal, 13(3), 389–420.

[7] Devereux, M. P., & Vella, J. (2022). Implications of digitalization for international corporate tax reform. Fiscal Studies, 43(1), 5–27. https://doi.org/10.1111/1475-5890.12312

[8] Mirrlees, J. A. (1971). An exploration in the theory of optimum income taxation. Review of Economic Studies, 38(2), 175–208.

[9] Mpofu, F. (2022). Tax challenges of the digitalized economy: A developing country perspective. Journal of African Taxation, Economic Policy and Management, 8(2), 133–152.

[10] Mpofu, F. Y. (2022). Taxation of the digital economy and direct digital service taxes: Opportunities, challenges, and implications for African countries. Economies, 10(9), 219. https://doi.org/10.3390/economies10090219

[11] Mpofu, F. Y., & Moloi, T. (2022). Direct digital services taxes in Africa and the canons of taxation. Laws, 11(4), 57. https://doi.org/10.3390/laws11040057

[12] Mpofu, F., & Moloi, T. (2022). Digital economy and tax base erosion in Africa: Issues and prospects. African Journal of Accounting, Auditing and Finance, 9(1), 1–21. https://doi.org/10.1504/AJAAF.2022.120458

[13] Musgrave, R. A., & Musgrave, P. B. (1989). Public finance in theory and practice (5th ed.). McGraw-Hill.

[14] Ndajiwo, M. (2020). The taxation of the digitalised economy: An African study (ICTD Working Paper 107). Institute of Development Studies.

[15] Nwankwo, C. B. (2025). Value Added Tax on digital services: An analysis of Nigeria’s approach towards global standards. Nnamdi Azikiwe University Journal of Private and Property Law, 2(1). https://journals.unizik.edu.ng/naujppl/article/view/5920

[16] Nwankwo, U. (2025). Significant economic presence and digital taxation in Nigeria: Legal and fiscal perspectives. African Journal of Law and Policy, 11(3), 101–120.

[17] OECD. (2021). Addressing the tax challenges arising from the digitalisation of the economy: Global anti-base erosion (GloBE) rules. OECD Publishing. https://doi.org/10.1787/0e3ab79e-en

[18] OECD/G20 Inclusive Framework. (2025). Addressing the tax challenges of the digital economy: Pillar One and Pillar Two. OECD Publishing.

[19] Oto, T. E., & Wayas, S. (2024). Taxation of digital economy in Nigeria: Challenges and prospects. Advance Journal of Banking, Finance and Investment, 8(2), 1–14. https://aspjournals.org/ajbi/index.php/ajbfi/article/view/16

[20] Owens, J., & Plekhanova, V. (2021). The taxation of digital services in developing countries: Challenges and opportunities. Bulletin for International Taxation, 75(4/5), 203–212.

[21] Singh, R., & Roy, S. (2022). Tax tribunals and specialized adjudication of digital taxation disputes in India. Indian Journal of International Economic Law, 14(1), 45–68.

[22] Smith, A. (1776). An inquiry into the nature and causes of the wealth of nations. W. Strahan and T. Cadell.

[23] Stiglitz, J. E. (2000). Economics of the public sector (3rd ed.). W. W. Norton & Company.

[24] Stollsteiner, G. (2024). Fair taxation in the digital age: Can the OECD Two-Pillar Solution replace Digital Services Taxes? Financial Law Review, 33(1), 1–15. https://czasopisma.bg.ug.edu.pl/index.php/flr/article/view/10756

[25] Stollsteiner, M. (2024). Rethinking permanent establishment in the era of digital services. World Tax Journal, 16(1), 55–79.

[26] United Nations. (2021). Taxation of the digitalized economy: Policy options for developing countries. UN Committee of Experts on International Cooperation in Tax Matters. https://www.un.org/development/desa/financing/

How to cite this paper

Uzor Chijioke Esq. "Taxation of Digital Services in a Globalized Economy: Implications for Nigeria and Africa" Iconic Research And Engineering Journals Volume 9 Issue 3 2025 Page 685-698 https://doi.org/10.64388/IREV9I3-1710538-079
Uzor Chijioke Esq. "Taxation of Digital Services in a Globalized Economy: Implications for Nigeria and Africa" Iconic Research And Engineering Journals, vol. 9, no. 3, Sep. 2025, doi: https://doi.org/10.64388/IREV9I3-1710538-079
Uzor Chijioke Esq. (2025). Taxation of Digital Services in a Globalized Economy: Implications for Nigeria and Africa. Iconic Research And Engineering Journals, 9(3). doi: https://doi.org/10.64388/IREV9I3-1710538-079
Uzor Chijioke Esq. "Taxation of Digital Services in a Globalized Economy: Implications for Nigeria and Africa" Iconic Research And Engineering Journals, vol. 9, no. 3, Sep. 2025. Crossref, https://doi.org/10.64388/IREV9I3-1710538-079
@article{1710538,
      author = {Uzor Chijioke Esq.},
      title = {Taxation of Digital Services in a Globalized Economy: Implications for Nigeria and Africa},
      journal = {Iconic Research And Engineering Journals},
      year = {2025},
      volume = {9},
      number = {3},
      pages = {685-698},
      issn = {2456-8880},
      url = {https://www.irejournals.com/formatedpaper/1710538.pdf},
      abstract = {The pace of digitalization of the world's economy has exposed the flaw of traditional international tax systems, particularly digital services. Multinational technology companies more and more make huge revenues across borders without physical presence, which creates severe challenges for states to exert taxing powers. This paper critically examines taxation of digital services in a global economy, notably Nigeria and Africa. Based on comparative and doctrinal analysis, the study canvasses international tax principles, OECD/G20 Inclusive Framework proposals, United Nations negotiations, and African national tax reforms. Evidence highlights that while unilateral measures such as Digital Services Taxes (DSTs) and Significant Economic Presence (SEP) regulations are lucrative in terms of short-term budgetary gains, they may also carry the risk of administrative inefficiency, double taxation, and potential disagreement in trade. Nigeria's new reforms, including the VAT imposition on non-resident digital providers and SEP actions, are important policy developments that are in the course of implementation but are hampered by the shortcoming of weak administrative capacity and deficit in compliance. Across Africa, similar experiences demonstrate a delicate balance between generating revenue and promoting digital innovation. Tenuously structured levies, such as mobile money, have in some cases jettisoned financial inclusion, demonstrating the risk of unilateral dependence. The report explains that solutions in the long term lie in enhancing domestic enforcement capacity, cooperating more robustly at the regional level through bodies like ECOWAS and the African Union, and engaging more intensively in multilateral tax talks. Lastly, the article argues that a balanced strategy?based on VAT reforms, collection at the platform level, harmonization of regional policy, and positive participation in global arrangements?has the best potential avenue for African countries. These initiatives can bring more equitable revenue sharing, protect digital inclusion, and more seamlessly integrate Africa into the new international tax architecture.},
      keywords = {Digital Services Tax, Globalization, International Taxation, Africa, OECD},
      month = {September},
      doi = {https://doi.org/10.64388/IREV9I3-1710538-079}
  }