Jurisdiction & corridor analysis

Offshore investment routes into Africa.

Choose an African market to compare the inward direct investment reported by the receiving country with the positions reported by offshore jurisdictions.

Country summary: Nigeria

Few African markets offer the breadth of commercial exposure available in Nigeria. With an estimated population of 232.7 million in 2024, the country combines a large consumer market with significant opportunities in energy, telecommunications, financial services, digital infrastructure, consumer goods, food processing, agriculture, manufacturing and logistics. Foreign capital committed to Nigeria is therefore seeking participation in domestic demand and productive assets, not simply access to the oil sector. Services now account for more than half of the economy, further broadening the investment proposition beyond Nigeria’s traditional dependence on hydrocarbons.

Actual FDI inflows remain modest relative to Nigeria’s investment potential. UNCTAD estimates that inward FDI rose from USD 895 million in 2022 to USD 1.87 billion in 2023, before declining to USD 1.08 billion in 2024. These annual flows are fundamentally different from the figures presented in the corridor chart. The chart shows the outstanding investment exposure at each year end, calculated as net equity plus gross debt liabilities by immediate counterpart jurisdiction. A USD 10 billion position therefore represents the exposure outstanding on the reporting date, not USD 10 billion of new investment received during that year.

Since May 2023, foreign investors have also had to reassess the economics of operating in Nigeria. Foreign exchange reform and the removal of the gasoline subsidy were intended to reduce market distortions and improve fiscal sustainability, but the transition brought a sharp depreciation of the naira, high inflation and greater pressure on operating costs and consumer spending. Nigeria remains an attractive investment destination because of its scale, natural resources and unmet demand. The return case, however, must be assessed against currency risk, power costs, financing conditions, regulatory execution and the practical ability to repatriate earnings.

Receiving-country record (USD million)

What Nigeria reports

2022-2024
Ranked OFC202220232024
1BermudaBMU · immediate counterpart
2Netherlands, TheNLD · immediate counterpart
3British Virgin IslandsVGB · immediate counterpart
014k014k014k

Source: IMF, Direct Investment Positions by Counterpart Economy (formerly CDIS). Data view: Reported official data — receiving country. Dataset 12.0.1; observation period 2022-2024; retrieved 21 July 2026.

Offshore-jurisdiction records (USD million)

What the offshore jurisdictions report

2022-2024
Ranked OFC202220232024
1Netherlands, TheNLD · immediate counterpart
2United StatesUSA · immediate counterpart
3MauritiusMUS · immediate counterpart
014k014k014k

Source: IMF, Direct Investment Positions by Counterpart Economy (formerly CDIS). Data view: Derived using counterparty information — offshore jurisdictions. Dataset 12.0.1; observation period 2022-2024; retrieved 21 July 2026.

Method and comparability notes

Why the charts may differ: Countries can report the same investment differently because of timing, valuation methods, reporting thresholds, confidentiality and missing submissions. Neither chart identifies the ultimate investor.

Method: Corpfin total IDI equals the IMF net equity position plus IMF gross debt liabilities. The receiving country figures and the figures derived from reports by the selected offshore jurisdictions are ranked separately and are never merged. Blank annual value cells in returned IMF series are treated as zero; absent series and explicit IMF missing or suppressed markers remain unavailable. Differences between the two views can result from reporting asymmetry, and neither view identifies the ultimate investor or establishes that a structure is tax-driven.

Professional assessment

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Indicative comparison

Compare holding routes for Nigeria

Test three approved holding jurisdictions against direct investment.

Compare three holding routes

IDI corridor interpretation

IDI to Nigeria from OFCs

Interpretation based on the receiving-country record; differences shown by the offshore-jurisdiction record are addressed in the comparative observations.

OFC1

Bermuda

2024 position · USD 7,117.00 million

At USD 7.12 billion, Bermuda was Nigeria’s largest reported offshore position in 2024. It had increased from USD 11.69 billion in 2022 to USD 12.24 billion in 2023, before falling by 41.9% in 2024. The close correspondence between that decline and the naira’s depreciation suggests that a substantial part of the movement may reflect the lower dollar value of Nigerian assets, rather than an equivalent withdrawal of capital.

A useful illustration is MRS Oil Nigeria. Its 2024 financial statements identify Bermuda incorporated MRS Africa Holdings Limited as the company’s 60% shareholder. The Nigerian business operates in petroleum product distribution and lubricant manufacturing, while the Bermuda shareholder is itself controlled by Corlay Global S.A. in Panama. The structure was retained after Corlay acquired Chevron’s former Bermudian African holding company. Bermuda therefore appears as the immediate counterpart because an established regional holding entity remained in the ownership chain, not because the ultimate investor is necessarily Bermudian.

Bermuda is used for internationally held businesses because its exempted company regime is expressly designed for companies conducting business outside the island. It offers established corporate law and experienced administration for holding and financing structures. There is no operational Nigeria and Bermuda double taxation agreement, so the corridor is better explained by corporate continuity and legal structuring than by a bilateral tax treaty.

OFC2

Netherlands, The

2024 position · USD 6,226.12 million

Here, the Dutch position was remarkably stable. It moved from USD 14.27 billion in 2022 to USD 14.13 billion in 2023 and USD 13.92 billion in 2024. The Netherlands consequently represented approximately 52% of the three offshore reported positions in 2024.

That stability is consistent with a mature stock of operating and holding investments. Alongside HEINEKEN and Shell, FrieslandCampina held 67.81% of FrieslandCampina WAMCO Nigeria. Dutch entities can also act as intermediate shareholders for non-Dutch groups. Unilever Nigeria, for example, was held through Unilever Overseas Holdings B.V., while the ultimate parent was in the United Kingdom. The corridor is therefore a mixture of genuinely Dutch investment, multinational capital routed through Dutch companies and related company finance.

Comparative observation

Compared with Bermuda or the BVI, the Netherlands offers a more complete combination of operating substance and treaty infrastructure. Its double taxation agreement with Nigeria has been in force since 1992, while the bilateral investment treaty has been in force since 1994. These arrangements provide tax coordination and investment protection around long established Dutch corporate interests. Nevertheless, some Dutch companies are intermediate holding entities for multinational groups headquartered elsewhere, so the position should not be treated as entirely Dutch ultimate capital.

OFC3

British Virgin Islands

2024 position · USD 5,745.90 million

Volatility is most visible in the British Virgin Islands corridor. Nigeria’s reported position more than doubled from USD 4.60 billion in 2022 to USD 9.81 billion in 2023, before falling to USD 5.75 billion in 2024. Even after that decline, the position remained approximately 25% above its 2022 level. The 41.4% reduction during 2024 again closely matches the naira translation effect, making a simple divestment explanation inadequate.

Corporate records illustrate why BVI entities appear in the data. ADM Energy’s structure includes ADM 113 Limited, a BVI holding company whose Nigerian subsidiary holds a 9.2% revenue interest in the offshore OML 113 licence. The BVI entity sits between the wider investor group and the Nigerian operating interest.

In practical terms, BVI companies are convenient for holding shares, separating project risk, bringing several investors into one vehicle and arranging asset specific finance. The jurisdiction permits its business companies to hold shares and enter a broad range of transactions, which helps explain its use for energy, infrastructure and private investment structures. The BVI has no operational double taxation agreement with Nigeria, so legal flexibility and efficient ownership structuring are more convincing explanations than treaty access.

Comparative observation

The reporting asymmetry between the two charts is material.

Mauritius tells a different story. Its reported position was comparatively stable at USD 5.96 billion in 2022 and USD 6.05 billion in 2023, before declining to USD 4.20 billion in 2024. The 30.5% fall was meaningful, but it was smaller than the naira’s depreciation and should not automatically be interpreted as capital flight.

MTN provides the clearest explanation of how this corridor works. MTN International (Mauritius) Limited held approximately 76% of MTN Nigeria, but the Mauritian company was controlled by MTN entities in South Africa. Mauritius is therefore the immediate investor jurisdiction, while the ultimate corporate origin is South African. The investment itself remains a substantial operating exposure to Nigeria’s telecommunications market.

For this route, Mauritius offers an established African investment holding environment, experienced professional administration and a familiar structure for managing regional subsidiaries. The Nigeria and Mauritius tax agreement has been signed but remains awaiting ratification, so the corridor cannot properly be attributed to an operative bilateral tax treaty. Its scale is better explained by established African corporate ownership structures such as MTN, together with the equity and related financing held through them.