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Why Nigeria Did Not Sign The OECD Minimum Corporate Tax Agreement – FIRS

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Why Nigeria Did Not Sign The OECD Minimum Corporate Tax Agreement - FIRS

“Nigeria has been involved in various work-streams under the OECD project”

Olushola Okunlade Writes

The Federal Inland Revenue Service (FIRS) has explained why Nigeria did not sign the Organisation for Economic Cooperation and Development (OECD) G20 Inclusive Framework two-pillar solution to tax challenges of the digitalized economy.

The OECD G20 Inclusive Framework two-pillar solution proposes a framework of rules aimed at tackling base erosion and profit shifting and providing for the taxation of Multinational Enterprises (MNEs). Four member countries of the Inclusive Framework (Nigeria inclusive), out of 140, have not agreed to the Two-Pillar solution.

Nigeria’s reasons for not agreeing to the Two-Pillar solution was explained in a webinar session hosted by the FIRS last week.

Why Nigeria Did Not Sign The OECD Minimum Corporate Tax Agreement - FIRS
Mr. Muhammad Mamman Nami, Executive Chairman of the FIRS.

The Executive Chairman of the FIRS, represented by the Group Lead, Executive Chairman’s Group, Mr M. L. Abubakar, noted that taxation of the digital economy has become a topical issue that many economies and developmental blocs are working to solve, including the OECD and the United Nations Tax Committee who have commissioned projects to produce a common front for countries to adopt.

“Nigeria has been involved in various work-streams under the OECD project and had articulated its position on the technical work towards the goal of producing a common front for countries. However, our concerns on potential negative revenue returns that the rule designs would have for developing countries were unaddressed, Nigeria abstained from committing to the rules at this time.” He stated.

He explained that the webinar was therefore to educate the general public on the modalities and impact of the statement released by the OECD Inclusive Framework on the 8th of October 2021 and to provide a broad picture on why Nigeria abstained from signing.  

The webinar which was a special edition of the FIRS Taxpayer Engagement Series was hosted by Mr. Olufemi Olarinde, Technical Assistant (Tax Policy) to the Executive Chairman FIRS, while technical papers were delivered by Mr. Mathew Gbonjubola, Mr Temitayo Orebajo, Mr Kehinde Kajesomo, Mr, Emmanuel Eze and Ms. Aisha Isa, all staff of the FIRS.

Explaining in detail, Mr. Mathew Gbonjubola, the Group Lead Special Tax Operations Group, and Nigeria’s representative at the OECD Inclusive Framework highlighted that despite the expected outcome that both Pillars will increase Global Corporate Income Tax by as much as $150 Billion per annum, with an attendant favourable environment for investment and economic growth, there were serious concerns that the pillars did not address negative revenue outcome for Nigeria and other developing countries.

“The general issue that developing countries have with the outcome that was published on October 8th is the high cost of implementation. And that speaks to the complexities of the proposal in the inclusive framework statement. In every complex situation or rule, implementation and compliance will always be difficult. When implementation or compliance is difficult, there would be the high cost of implementation.

“Another issue was that the economic impact assessment that was carried out on Pillar 1 and 2 were founded on an unreliable premise. The country-specific impact assessment that was done was top-down. Somebody just looked at the GDP of Nigeria and says Nigeria’s GDP is this much and then they should be able to buy this number of shoes and things like that. And you and I know, in that kind of postulation, the margin of error is usually very wide. That exactly was what happened with this. Particularly for Nigeria, when we ran the numbers it was way off the figures that the OECD gave us.

“And the final issue most developing countries had was that the developed world, within the inclusive framework, was very indifferent to the concerns expressed by most developing countries. This you can see from the outcome, with respect to the complexity, issues of the high cost of implementation and on the issue of revenue accruable to developing countries. When you look at the bulk of the money that would accrue from the project, if any, 70% – 80% will go to the developed countries. Almost nothing comes to the developing countries.” He explained.

On the specific concerns raised by Nigeria, Mr. Gbonjubola, who led Nigeria’s team on the Inclusive Framework negotiations, explained that while the whole project started out to find solutions to the challenges of a digitalised economy the outcome was completely different.

He went further to note that the statement by the OECD Inclusive Framework required all parties to remove all Digital Service Taxes and other relevant similar measures with respect to companies taxation and to commit not to introduce such measures in the future.

“The statement required the withdrawal of unilateral measures by countries. Which Nigeria does not have a problem with (Nigeria does not have any unilateral measure targeted at digital services companies). However, the paper that was released on unilateral measures was so expansive in its definition that we are concerned that the taxing rights that Nigeria has always enjoyed may be withdrawn.”

He further explained that Nigeria is unable to implement the mandatory binding resolution on arbitration because of constitutional limitations as to tax dispute resolution.

He also stated that for Nigeria, “Pillar 2 is not a deal-breaker because Nigeria could work with Pillar 2. “We have a few issues with Pillar 2 but we could live with them but because Pillar 1 and 2 are a single package, since we are rejecting Pillar 1, we can’t take on Pillar 2”.

“Under the inclusive framework rule you either accept both Pillars or you reject both Pillars. You cannot pick one to the exclusion of the other. And since Nigeria is not able to join one of the pillars, it means we are out of both Pillars.”

Mr. Gbonjubola also stated that Nigeria does not see any additional revenue coming to by way of Pillar 2, though he added that it could act as a behaviour modifier for policy makers to take another look at the various tax incentives and tax waivers we have in our tax laws and begin to restructure them in other to ensure that we are not deliberately throwing away revenue.

“Nigeria could not sign up to the statement of the inclusive framework because it did not address the concerns that we had expressed as a country and it also did not take cognisance of issues around developing countries, which will make those outcomes not to provide additional revenue, and if any, very little, and at very significant cost.”

He further stated that Nigeria, which had participated in all the meetings of the working groups would continue to participate in the design of all technical notes and model rules, and would agree to the Pillars if its expressed concerns are addressed.

“And finally, just like the Honourable Minister of Finance said a couple of months ago, Nigeria would continue to participate in the inclusive framework activities particularly the design of all the technical notes and the model rules, and then, if and only if, the concerns we have expressed are addressed, then Nigeria still has the chance to join up and to sign up. But if not, we will leave that to our policymakers to decide going forward”

The Webinar had in attendance Prof. Abiola Sani, a professor of Commercial Law in Nigeria as well as other eminent tax practitioners and representatives of government and private institutions. The representatives of the Kenya and Zambia revenue authorities were also in attendance.

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Fitch Upgrades Fidelity Bank’s Issuer Default Rating From ‘B-’ To ‘B’

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Fidelity Bank CEO - Mrs Nneka Onyeali-Ikpe (1

Olushola Okunlade Writes

Fitch Ratings has upgraded Fidelity Bank Plc’s long-term issuer default rating (IDR) from ‘B-’ to ‘B’, reflecting the bank’s increased creditworthiness.

The rating agency also upgraded Fidelity’s National Long-Term Rating to ‘A(nga)’ from ‘BBB+(nga)’.

According to the global rating agency, the upgrade is a result of the Bank’s improving business profile and resilient financial metrics. The agency added that the improved rating reflected the bank’s increased creditworthiness relative to other issuers in Nigeria, emphasizing that, “Fidelity’s Long- and Short-term IDRs are driven by its standalone creditworthiness, as expressed by its Viability Rating (VR) of ‘b’ ’’.

The agency further stated that the VR reflects healthy asset quality, a good business profile, and reasonable capitalization and liquidity. These are balanced against high sensitivity to Nigeria’s challenging operating environment as well as higher credit concentration as a percentage of equity and weaker profitability than larger domestic-rated peers.

Fidelity Bank CEO - Mrs Nneka Onyeali-Ikpe (1
Fidelity Bank CEO, Mrs. Nneka Onyeali-Ikpe.

Commenting on the upgraded rating, Nneka Onyeali-Ikpe, Managing Director/CEO, Fidelity Bank Plc, stated, “Receiving this upgrade at a time when the global economy is faced with a myriad of challenges, speaks to the strength of our business model, the efficacy of our risk management culture and the commitment of our staff towards creating sustainable value for all stakeholders.  As a bank, we will continue to execute our growth strategy in a prudent manner that allows us to take advantage of emerging opportunities in our various markets”.

Fidelity Bank is a full-fledged commercial bank operating in Nigeria with over 6.5 million customers serviced across its 250 business offices and digital banking channels. The bank was recently recognized as the Best SME Bank Nigeria 2022 by the Global Banking & Finance Awards. The bank has also won awards for the “Fastest Growing Bank” and “MSME & Entrepreneurship Financing Bank of the Year” at the 2021 BusinessDay Banks and Other Financial Institutions (BAFI) Awards.

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Unity Bank Corpreneurship Challenge: Delta, Rivers Corps Members Listed To Benefit From N10m Business Grant

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Unity Bank Corpreneurship Challenge: Delta, Rivers Corps Members Listed To Benefit From N10m Business Grant

Olushola Okunlade Writes

Unity Bank’s flagship Entrepreneurial Development Initiative, Corpreneurship Challenge, is set to return for the 8th edition across 10 locations in Nigeria, including a debut in Delta and Rivers States.

The Retail lender kick-started the Corpreneurship Challenge scheme in 2019, with a launch in Lagos and in three other states, which included Edo, Ogun, and Abuja, but with the increasing traction of the initiative among corps entrepreneurs, the Bank has now expanded the program to 10 states across the federation.

The first expanded edition covered Lagos, Ogun, Abuja, Edo, Katsina, Enugu, Bayelsa, Akwa Ibom, Sokoto, Kano, and Kaduna. This edition will hold for the first time in Rivers and Delta as well as making a return to Sokoto, Edo, Abuja, Akwa-Ibom, Osun, Kano, Bayelsa, and Enugu.

The Corpreneurship Challenge, which has earned the Bank a national recognition for its impact on youth empowerment and job creation, has continued to elicit growing interest among the corps members, attracting over 2000 applicants and participation in every edition.

In partnership with the NYSC Skill Acquisition and Entrepreneurship Development, SAED, the initiative prominently features a business pitch presentation that provides the participants with the opportunity to present their business plans and stand a chance to win up to N500, 000 cash in the business grant.

Previous editions saw participants pitching business plans from several sectors including software solutions, fashion, fish production, poultry farming, bee farming, retail chains, and piggery to beverages which were assessed based on originality, marketability, and future employability potential of the product and knowledge of the business.

So far, Unity Bank has invested over N100 million in the initiative which has now produced 58 winners since it was launched.

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Fidelity Bank Partners ImpactHER To Empower 1,052 Female Entrepreneurs With Sales Skills

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Fidelity Partners ImpactHER to Empower 1,052 Female Entrepreneurs with Sales Skills

Olushola Okunlade Writes

Fidelity Bank, a leading financial institution in Nigeria, has collaborated with ImpactHER to support 1,052 female entrepreneurs across the 36 states of Nigeria in addressing the challenges they face in their small and medium-sized businesses. 

Through diverse training on digital skills and direct business support, beneficiaries from two cohorts have been able to improve visibility for their businesses and consequently, increase sales.

The training, which commenced in January 2022, has had two cohorts that lasted for four weeks each, covering a myriad of topics such as Digital marketing, building your brand and selling online, etc. The participants were also assisted in putting their businesses on Google Maps, thus allowing customers and the global market to easily find and transact business with them.

Commenting on the partnership, Osita Ede, Divisional Head, Product Development at Fidelity Bank Plc said, “It has become imperative that female entrepreneurs in Africa are empowered to overcome the lack of digital literacy which impedes them from fully reaping the benefits of the digital transformation underway across  Africa, and the world. We believe providing them this access will help them to thrive in their different businesses.”

According to Efe Ukala, Founder of ImpactHER, “Statistically, women and girls are 25 per cent less likely to leverage digital technology for basic purposes, 4 times less likely to know how to program computers, and 13 times less likely to file for technology patents. This, therefore, highlights the importance of equipping African women with digital skills that could be leveraged to scale their businesses. Let’s not  forget that data shows that Africa can add 180 billion Dollars to its  GDP by 2025 if we close the e-commerce digital gap.”

This intervention is critical as the Global Entrepreneurship Monitor for  2019/2020 highlighted that millions of women worldwide have started businesses over the last five years alone: the highest percentage of these women live in Africa, with approximately 26% of female adults engaged in entrepreneurial activity yet the World Bank confirms through data collected in ten African countries that on average,  male-owned companies have six times more capital than female-owned enterprises, resulting in monthly profits of female-owned enterprises that are, on average, 38% lower than male-owned  businesses.

Fidelity Bank is a full-fledged commercial bank operating in Nigeria with over 6.5 million customers serviced across its 250 business offices and digital banking channels. The bank was recently recognized as the Best SME Bank Nigeria 2022 by the Global Banking & Finance Awards. The bank has also won awards for the “Fastest Growing Bank” and “MSME & Entrepreneurship Financing Bank of the Year” at the 2021 BusinessDay Banks and Other Financial Institutions (BAFI) Awards.

The bank boasts of a robust bouquet of products designed to help female-led small businesses run successfully including digital loans and HerFidelity -a proposition comprising exciting features such as capacity development initiatives, access to finance, recognition and networking events, health and wellness programmes, etc, all designed to speak to the yearnings of women.

Clementina Uzogor, the Programs Director at ImpactHER, highlighted the importance of helping women with skills like this to take their businesses to the next level. “At ImpactHER, it is our mission to ensure that we equip these women with tools for their businesses to thrive”,  she explained.

She also appreciated Fidelity Bank for working with them to ensure the  programme was successful and impactful. “It is important to let you  know that this is not the end of this training. We will be deepening our partnership with Fidelity to train and support 5,000 more women-led small and medium-sized businesses in the country before the year runs  out”, she divulged.

An excited participant from the second cohort, Ms. Akinyemi  Oluronke, a fashion designer from Lagos underscored the benefits of joining the training for her business, “I’ve been able to build an online presence, people now know my business exists and I get a lot of calls from people who found my business online. I am very grateful for this  platform and the overall increase in sales I now enjoy.” 

According to Carine Nneka Achokwu, another participant from the  January 2022 cohort and CEO of Carine Bakery, a company that  produces pastries and cakes in Lagos, Nigeria, “I have been able to  increase sales by 40% after using the tools that was provided to me such as “Google My Business” and people have been calling to order  from me and I’ve also been able to reach more customers. I am  thankful that I can get people to patronize my business just by tapping  my phone based on the knowledge I acquired at this training.” 

ImpactHER is an impact-driven nonprofit organization that empowers  African female entrepreneurs by bridging the gender business financing gap so as to assist them in realizing their full economic potential. ImpactHER has since its inception trained, and directly supported with investor-readiness and business scalability skills & tools over 44, 275 women across 53 countries in Africa.

This partnership also provides follow-up training and support for the participants and is one of the ways ImpactHER and Fidelity Bank help these women scale up their offerings.

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