The standard FEMA-governed NRE, NRO, and FCNR account framework applies to NRIs connected to Nigeria exactly as it does elsewhere, but because no India-Nigeria DTAA exists, treaty-based relief under Sections 90/90A is not available on India-source income.
NRE, NRO and FCNR accounts for NRIs connected to Nigeria
An NRI connected to Nigeria uses the same three account types as NRIs elsewhere: an NRE account for
foreign earnings (freely repatriable, tax-free interest for a non-resident), an NRO account for
India-sourced income (repatriation-restricted, taxable), and an FCNR account for foreign-currency term
deposits. With an Indian community the High Commission of India, Abuja describes at approximately 50,000
and more recent estimates putting at approximately 60,000 -- the largest Indian diaspora in West Africa --
this is a substantial and well-established NRI banking population.
Repatriation limits, and the absence of treaty relief
FEMA rules permit repatriation abroad of up to USD 1 million (or equivalent) per financial year from
an NRO account, cumulative across eligible remittances, subject to the authorized dealer bank receiving
Form 15CA (and Form 15CB where applicable). Because no India-Nigeria DTAA currently exists, treaty-based
relief under Sections 90/90A of the Income Tax Act is not available on India-source income connected to
Nigeria -- this is a genuinely important difference from most other countries this platform covers, where
treaty relief is generally available. An NRI connected to Nigeria should plan for standard Indian
withholding rates without treaty mitigation.
Practical notes given Nigeria's substantial, long-established Indian business community
Because Nigeria's Indian community includes a large, multi-generational, and economically dominant
business population -- Indian firms are described by the High Commission as the second largest employer
in Nigeria after the Federal Government -- compliance questions here can range from long-settled business
families managing established Nigerian companies alongside Indian assets, to newer professionals and
investors navigating NRI status for the first time. Given the current security advisory covering parts of
Nigeria, families should also keep emergency and consular contact information current as part of an
overall compliance and safety picture.
Common mistakes in this area for NRIs connected to Nigeria:
- Assuming treaty-based DTAA relief is available on India-source income, when no India-Nigeria
treaty currently exists.
- Not accounting for standard, unmitigated Indian withholding rates when planning remittances.
- Leaving Form 15CA/15CB paperwork until after funds reach the NRO account, delaying repatriation.
