Provisions of Tax Laws to Mitigate Double Taxation:
As the Tax Consultant to Rev. (Dr.) Smart, the following provisions of the Nigerian Tax Laws and international taxation principles will help mitigate the impact of double taxation on his income:

1. Residency Rule for Taxation:
   • Rev. (Dr.) Smart is deemed a resident of Nigeria since it is his permanent home.
   • Under Nigerian law, residents are taxed on their worldwide income, but relief is available for taxes paid in other jurisdictions.
2. Double Taxation Agreements (DTAs):
   • Nigeria has Double Taxation Agreements with several countries, including the UK, Canada, South Africa, and others.
   • These agreements allow for the avoidance of double taxation by providing relief either through tax credits or tax exemptions.
3. Unilateral Relief:
   • Where no DTA exists between Nigeria and a country Rev. (Dr.) Smart worked in, Nigeria’s unilateral relief provision allows foreign taxes paid to be deducted as a tax credit against his Nigerian tax liability.
4. Exemptions for Short-Term Visits:
   • Under many DTAs, income earned in a foreign country is not taxable there if:
     a. The stay is less than 183 days in a 12-month period.
     b. The payment is made by a non-resident employer.
     c. The income is not borne by a permanent establishment in that foreign country.
5. Tax Credits and Evidence:
   • Rev. (Dr.) Smart must maintain proper documentation of taxes paid in each country, such as tax receipts or withholding tax certificates.
   • These documents are essential for claiming tax relief in Nigeria.
6. Source Rule in Host Countries:
   • For income earned in countries where he has stayed for more than the stipulated threshold (e.g., 183 days), taxes will be payable there, but these can be claimed as a credit in Nigeria.
7. Role of OECD Guidelines:
   • As Rev. (Dr.) Smart operates internationally, adherence to OECD Model Tax Convention principles ensures fair taxation and reduces the risk of disputes over double taxation.

By leveraging these provisions, Rev. (Dr.) Smart can effectively reduce his tax burden and ensure compliance across all jurisdictions where he earns income.