1. Key areas of potential fiscal cooperation between Nigeria and South Africa Nov 2014

2. PwC Republic of South Africa Slide 2 Most developed country in Africa Second largest economy in Africa by GDP 25th-largest country in the world by land area, and with over 50 million people, is the world's 25th-most populous nation a multiethnic society - wide variety of cultures, languages, and religions Abundant natural resources Member of BRICS nations

3. PwC Federal Republic of Nigeria Slide 3 A federal republic with 36 states and an FCT Largest economy in Africa Most populous country in Africa and the 7th most populous in the world Rich culture and diversity - over 250 ethnic groups Nascent democracy Consistently high economic growth and significant untapped opportunities – Next 11, MINT

4. PwC … key areas of fiscal cooperation Slide 4 What do we need? Mutual interest Mutual respect Political will More openness / trust Collaboration not competition Transfer pricing / BEPS Avoidance of double taxation Tax admin capacity building Exchange of information Over 300 companies do business in both Nigeria & South Africa

5. “It always seems impossible until it’s done.” – Nelson Mandela © 2014 PricewaterhouseCoopers. All rights reserved. In this document, “PwC” and “PricewaterhouseCoopers” refer to PricewaterhouseCoopers Nigeria which is a member firm of PricewaterhouseCoopers International Limited, each member firm of which is a separate legal entity. Thank you!

6. Contact Taiwo Oyedele Partner/ Head of Tax & Regulatory Services PricewaterhouseCoopers, Nigeria 252E Muri Okunola Street Victoria Island, Lagos Direct: +234 (1) 271 1700 Ext 6103 Mobile: +234 (0) 805 750 9237 Email: taiwo.oyedele@ng.pwc.com Website: www.pwc.com/ng Blog: www.pwc.com/nigeriataxblog LinkedIn: http://www.linkedin.com/pub/taiwo- oyedele/4/78/129 Facebook: http://www.facebook.com/taiwo.oyedele Twitter: @taiwoyedele