Digitalization has transformed data value chains in different ways, opening up channels for value addition. These channels take the form of data-driven, consumer-facing business models. The emergence of these platform-based business models has eroded the need for physical proximity to target market. It becomes necessary that, in a digital age, the allocation of taxing rights by a state can no longer be exclusively limited by reference to physical presence. In response to the need to remedy this tax challenge, Nigeria introduced a new taxing right through the concept of significant economic presence (SEP)