State pension, pension and tax in Nigeria: what the 1991 treaty arranges
The Netherlands and Nigeria have had a tax treaty since 1993. The Netherlands taxes your AOW and a government pension, Nigeria an ordinary company pension. There is no social security treaty: a single person gets the AOW for married people in Nigeria, and the supplement, the Anw and child benefit don't come along.
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If you live in Nigeria, the Netherlands keeps taxing your AOW, the Dutch state pension, and Nigeria taxes your ordinary company pension. That is how the tax treaty the Netherlands and Nigeria signed in Lagos on 11 December 1991 divides it. It has been in force since 9 December 1992 and applies from 1 January 1993. The Belastingdienst lists it per type of income in its overview of January 2026. There is no social security treaty, and that costs a single person a considerable part of their AOW.
Who taxes which income?
| Income | Taxed according to the Belastingdienst by | Treaty |
|---|---|---|
| AOW, Anw, WAO, WIA, Wajong | the Netherlands | article 19(2) |
| Government pension (such as the ABP) | the Netherlands | article 19(2) |
| Company pension from a pension fund, also from a state-owned company | Nigeria | article 18(1) |
| Pension managed by your own company | exception: the Netherlands may tax | article 18(1)(a) |
| Annuity (lijfrente) | the Netherlands | article 18(2) |
| Commutation of an annuity | the Netherlands | article 22(2) |
| Interest on money you lend to your own company | the Netherlands at most 12.5 % | article 11(2) |
| Dividend from a substantial interest (box 2) | the Netherlands at most 15 % | article 10(2) |
What does that mean for your AOW?
The Netherlands may tax your AOW, and the SVB then withholds wage tax. Nigeria taxes its residents on all their income, wherever it comes from (section 12 of the Nigeria Tax Act 2025), and "any pension, annuity" counts too. The treaty deals with the double taxation: Nigeria credits the Dutch tax against the Nigerian tax on the same income (article 23(4)).
On your AOW, the SVB only gives you the premium part of the wage tax credit, and only if you are still insured for a national insurance scheme. You don't get the tax part through the SVB. What you might get back through a tax return is in where is your pension taxed.
And your company pension?
Under article 18, an ordinary company pension from a pension fund is taxable only in your country of residence. Your pension fund then stops withholding wage tax, if you apply to the Belastingdienst for an exemption. For that you need a citizen service number (BSN), and proof that you are a tax resident of Nigeria, with the form "Verklaring belastingplicht woonland".
Nigeria then taxes that pension as income, with rates rising from 0 percent on the first N800,000 to 25 percent above N50,000,000. The exemption in the act applies to pensions under the Nigerian Pension Reform Act, not to a Dutch pension. A government pension, such as the ABP, stays taxed in the Netherlands.
What does the missing social security treaty mean?
Nigeria is not among the 36 countries and territories outside the EU, the EEA and Switzerland with which the Netherlands has a social security treaty. According to the minister, no benefit goes to such countries "with the exception of the AOW pension at the level of the married rate". For a couple this changes nothing about the AOW. A single person drops from 70 to 50 percent of the minimum wage (section 9a of the AOW).
If you are single, calculate with the AOW for married people, not with your current statement. The supplement for a younger partner stops (section 8a), and an Anw survivor's benefit doesn't go to Nigeria. Child benefit also stops for a child living in Nigeria (section 7b of the General Child Benefit Act).
There is no healthcare arrangement through the CAK either; see healthcare in Nigeria.
Are you leaving before your AOW age?
Anyone who goes to live outside the Netherlands is usually no longer insured for the AOW, according to the SVB. Each year without insurance later means 2 percent less AOW. You apply for voluntary insurance within a year after you are no longer insured. More in AOW when emigrating.
What else doesn't the Netherlands let go?
An annuity or pension entitlement can get a protective assessment when you emigrate: an assessment that stays open, and that you only pay if you do something on which you would have to pay tax in the Netherlands, such as commuting it. Within the EU, deferral of payment is automatic; outside the EU you request it in writing. The deferral runs for at most ten years. See the protective assessment when emigrating.
So you don't become tax-free in Nigeria. The Netherlands keeps the AOW, your government pension and your annuity; Nigeria gets your company pension. Whether you may live there depends on who you are: the residence routes.
In Vertrekklaar this is phase 1 of 5 of the journey, step 1.2: the same steps, but for your situation — in your order, tickable, and with the deadlines watched. See the whole journey to Nigeria or go straight to step 1.2 in the open plan.
What this means for your numbers →
What this rests on
The facts in this article come from these official pages. Rules change. When in doubt, go by the source, not this article.
- Dutch Tax Administration — which deductions and tax credits you have when you live outside the Netherlands — belastingdienst.nl
- Belastingdienst — Treaty states income tax non-residents, January 2026 (Nigeria, columns NL and NGA) — download.belastingdienst.nl
- Netherlands–Nigeria tax treaty (Lagos, 11 December 1991), articles 18, 19, 23 and 29, with protocol — wetten.overheid.nl
- Belastingdienst — applying for exemption from wage tax, with the statement of tax liability in the country of residence — belastingdienst.nl
- SVB — what is deducted from your AOW outside the Netherlands, and the wage tax credit — svb.nl
- Answers to parliamentary questions 2024Z02891 — the 36 treaty countries for the AOW, and no export to other countries except the AOW for married people — open.overheid.nl
- General Old Age Pensions Act — section 9a, the married rate outside the Netherlands, and section 8a, no supplement — wetten.overheid.nl
- General Child Benefit Act, section 7b — no child benefit for a child outside the Netherlands — wetten.overheid.nl
- SVB — each uninsured year 2 % less AOW, and voluntary insurance within a year — svb.nl
- Belastingdienst — the protective assessment and deferral outside the EU (tax return notes 2026) — belastingdienst.nl
- Nigeria Tax Act 2025, section 12, the exemptions and the rates (Fourth Schedule) (via LIRS) — lirs.gov.ng
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