Nigerian Supreme Court ruling on Barclays Bank representative office

The Nigerian Supreme Court has ruled in the case of Peter Oluwafemi Atoyebi, SAN v. Barclays Bank Plc & Anor. that Barclays Bank conducted banking business in Nigeria through its representative office, Barclays Groups Representative Office (Nigeria) Limited.

The court found that the representative office attracted customers, facilitated communications, and served as a point of contact for the bank. While the case originated from a dispute regarding dishonoured cheques and allegations of breach of contract and negligence, the ruling carries significant tax implications. The decision suggests that a representative office of a foreign bank may constitute a permanent establishment in Nigeria, impacting how foreign financial institutions are taxed under the Nigeria Tax Act, 2025.