The emergence of the internet has turned the world into a 
Global village. People across the Globe and in all walks of 
life can now transact business with one another without 
geographical limitations. Thus, it has become possible for 
Multinational enterprises (MNEs) and other non-resident 
companies (NRCs) in the West or anywhere to deal with 
their targets in other regions, such as Africa, without the 
necessity of physical presence or the incorporation of a 
subsidiary in the region or country of interest. The result is 
that the countries where those goods or services are sold 
(the market jurisdictions) are deprived of the opportunity 
of taxing those MNEs or NRCs because the extant 
traditional international tax regime relies heavily on 
physical presence in a tax jurisdiction. To remedy the 
situation, several countries of the world, including Nigeria, 
came up with the idea of unilateral digital services tax 
which puts the MNEs at risk of multiple taxations on the 
same stream of income. The Inclusive Framework (IF) on 
Base Erosion and Profit Shifting (“BEPS”) led by the 
Organization for Economic Cooperation and Development 
(“OECD/G20) is primarily set up to resolve the problems 
of digital taxation that often lead to multiple taxation in 
several jurisdiction or no taxation at all. The OECD/G20 IF 
came up with a resolution on how to tax digital earnings –
especially in market jurisdictions. The opposition to this 
proposal comes mainly from developing economies. 
Nigeria is one of the countries that have not signed up to 
this proposal. The sum of the views against the agreement 
is that the OECD/G20 IF does not favor developing 
countries with low gross domestic product. This paper evaluates the rationale for Nigeria’s refusal to endorse the 
OECD/G20 IF. It further evaluates the possible benefits 
that may accrue from the deal; and makes a case for 
harmonization of conflicting interests for the benefits of the 
parties at both ends.