FIRS and Cross-Border Transactions: Addressing International Tax Challenges faced by Nigerian Businesses.


In an increasingly globalized business environment, Nigerian businesses are engaging in cross-border transactions to expand their reach and tap into international markets. While these opportunities bring growth and diversification, they also introduce complex international tax challenges. The Federal Inland Revenue Service (FIRS) recognizes the importance of addressing these challenges and ensuring that Nigerian businesses navigate international taxation efficiently and compliantly. In this article, we will explore the international tax challenges faced by Nigerian businesses engaged in cross-border transactions and how FIRS is working to provide solutions.

International Tax Challenges for Nigerian Businesses:

  1. Transfer Pricing: Transfer pricing refers to the pricing of goods, services, or intellectual property transferred between related entities in different countries. It is a major concern for Nigerian businesses engaged in cross-border transactions, as incorrect pricing can lead to tax evasion allegations. FIRS has adopted transfer pricing regulations that align with international standards to ensure fair pricing and prevent base erosion and profit shifting (BEPS).
  2. Double Taxation: Cross-border transactions often involve taxation in multiple jurisdictions, leading to the risk of double taxation. This occurs when two or more countries claim the right to tax the same income. FIRS has been proactive in negotiating double taxation treaties with various countries to mitigate this issue, ensuring that businesses are not unfairly taxed on the same income.
  3. Thin Capitalization Rules: Nigerian businesses that rely heavily on debt financing for their international operations may face thin capitalization rules. These rules limit the tax deductibility of interest payments on excessive debt. FIRS has guidelines in place to determine the appropriate debt-equity ratio and prevent profit shifting through excessive interest deductions.
  4. Withholding Taxes: Cross-border transactions often involve the withholding of taxes on payments made to non-resident entities. FIRS has established withholding tax regulations and rates to ensure the appropriate deduction and remittance of taxes on international payments.

FIRS Initiatives to Address International Tax Challenges:

  1. Transfer Pricing Compliance: FIRS has established a Transfer Pricing Unit responsible for ensuring that Nigerian businesses comply with international transfer pricing rules. This unit conducts audits, issues guidelines and provides training to businesses to enhance their understanding of transfer pricing regulations.
  2. International Tax Agreements: FIRS actively negotiates and enters into double taxation agreements (DTAs) with various countries to provide relief from double taxation. These agreements clarify taxing rights and provide mechanisms for dispute resolution.
  3. Enhanced Reporting Requirements: FIRS has introduced stringent reporting requirements for businesses engaged in cross-border transactions. This includes the submission of transfer pricing documentation and country-by-country reports to enhance transparency and compliance.
  4. Capacity Building: FIRS is investing in the capacity building of its staff to ensure they have the expertise to address international tax challenges effectively. This includes training in transfer pricing methodologies, BEPS guidelines and international tax law.

Collaboration with Tax Professionals:

Navigating the complexities of international taxation requires expertise in international tax law and regulations. Nigerian businesses are encouraged to collaborate with tax professionals and accounting firms with experience in international taxation to ensure compliance and optimize their tax positions. These professionals can provide guidance on transfer pricing, withholding taxes and international reporting requirements.


As Nigerian businesses continue to expand globally, international tax challenges will remain a critical consideration. FIRS plays a pivotal role in addressing these challenges by implementing regulations, negotiating DTAs and enhancing compliance measures. To succeed in the international marketplace, businesses must proactively engage with FIRS and seek expert guidance to navigate the intricate landscape of international taxation while contributing to Nigeria’s economic growth and development.

For professional advice on Accountancy, Transfer Pricing, Tax, Assurance, Outsourcing, online accounting support, Company Registration, and CAC matters, please contact Sunmola David & CO (Chartered Accountants & Tax Practitioners) at Lagos, Ogun state Nigeria offices, You can also reach us via WhatsApp at +2348038460036.