Panel: Dotun Adekunle (OPay) · Tim Siloma (PwC) · Olamide Obajimi (Ed Tax Practices Group) | FintechNGR Outlook Webinar, 24 February 2026
The panel at the FintechNGR 2026 Outlook Webinar brought together an operator, a Big Four tax partner, and a commercial lawyer. Their perspectives differed; their conclusion was the same: fintechs that treat the new tax regime as a strategic input — not merely a compliance burden — will emerge structurally stronger.
- The OPay Lesson: Operational Precision Is a Tax Strategy
When OPay began passing through legally mandated charges, the reaction on social media was fierce. COO Dotun Adekunle clarified: OPay was not introducing a new tax. The law had long existed; what changed was who should bear the liability. The real lesson, however, was operational. At the scale of millions of daily transactions, even a small misclassification creates material exposure. OPay’s immediate response was precision: separate revenue from pass-through funds, tighten transaction categorisation, align finance, tax, product, and engineering teams, and ensure every transaction is backed by defensible records.
For founders building today, Adekunle’s advice is to build flexibility from day one — modular fee structures, configurable tax logic in a transaction rules engine, and tax outcomes simulated before pricing is finalised. Those launching now are in a privileged position: they can design the right architecture from inception rather than retrofitting a legacy system under pressure.
“Growth that is not structurally compliant is fragile.” — Dotun Adekunle, COO, OPay
- The PwC View: A New Era of Radical Tax Transparency
Tim Siloma of PwC framed the reform as the arrival of a third certainty in Nigeria — beyond death and taxes — radical tax transparency powered by technology. The government is building a single source of truth, unifying data from the FIRS, the Nigerian Stock Exchange, Customs, and other agencies. Fintechs, as technology and data providers by nature, are well placed to co-create this infrastructure rather than simply be subject to it.
On holding structures, Siloma was candid: there is no universal answer. The right structure depends on business type, revenue scale, and exit model. Companies below ₦250 million in assets and under a million dollars in revenue qualify for zero CIT and need not over-engineer their setup. Those scaling globally must account for the 15% minimum effective tax rate, controlled foreign corporation rules, and significant economic presence exposure. The consistent advice: workshop the structure at formation, with advisers, and do not wait for a fundraising round to force the question.
- The Legal Lens: Contracts Must Change
Olamide Obajimi of Ed Tax Practices Group focused on an overlooked dimension: the commercial agreements fintechs sign every day. Two provisions demand immediate attention.
- Stamp duty must be explicitly allocated in every agreement. If it is not addressed, the party that ends up bearing it will feel the margin compression. Moderator Toyin Olufon confirmed she has seen this play out to painful effect in finalised contracts.
- Cross-border VAT is a live obligation. Non-resident providers delivering digital services into Nigeria must register for Nigerian VAT. If they have not, the liability falls on the Nigerian company. Every offshore software, infrastructure, or API relationship requires active due diligence.
- Significant Economic Presence means a non-resident company earning income from Nigeria may be taxable here regardless of physical presence — another reason cross-border agreements must reflect both Nigerian tax law and applicable double-tax treaties.
Obajimi also highlighted the binding tax ruling mechanism as one of the most powerful — and underutilised — protections now available. Under the new Nigerian Tax Administration Act, a written ruling from the tax authority is legally binding on that authority. For fintechs in areas of genuine ambiguity — crypto, peer-to-peer lending, embedded finance — obtaining a ruling before proceeding at scale is a meaningful risk management tool.
“Tax was once considered an improper basis for structuring decisions. That is no longer a credible stance. Tax is a decisive factor.” — Olamide Obajimi, Partner, Ed Tax Practices Group
Bottom line: Tax is no longer a back-office function. It is a product design constraint, a pricing input, a structural consideration, and a board-level conversation. The fintechs that build this understanding from the ground up will be more efficient, more fundable, and more resilient than those that discover their exposure late.
All content drawn exclusively from the FintechNGR 2026 Outlook Webinar transcript, 24 February 2026.