Olaniwun Ajayi LP

The Economics Behind The 2026 Deep Offshore Tax Remission Order

President Bola Ahmed Tinubu signed the Deep Offshore Oil and Gas Projects Incentives (Tax Remission) Order, 2026 (the Order), marking the latest development in Nigeria’s fiscal incentive framework for deep offshore operations. It builds upon the incentive regime first introduced by the Oil and Gas Companies (Tax Incentives, Exemption, Remission, etc.) Order, 2024 and the Notice of Tax Incentives on Deep Offshore Oil and Gas Production, 2024.

The Order retains the Standard Production Tax Credit for qualifying deep offshore developments and introduces two new mechanisms. The first is a Supplementary Production Tax Credit, available on a case-by-case basis for projects requiring additional fiscal support. The second is a Profit Oil Reset, which restarts the profit-sharing terms for qualifying new developments. These are complemented by updated ring-fencing provisions and a compliance and enforcement framework, including powers to withdraw incentives, and provisions aligning with the tax incentive reporting obligations introduced under the Nigeria Tax Act and the Nigeria Tax Administration Act.

In our latest newsletter, we examine the Order’s key provisions, analyse how they interact with the broader fiscal architecture, and consider what they mean in practice for operators, investors, and other stakeholders in Nigeria’s deep offshore sector.

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