Recent Developments in Transfer Pricing: Key Updates and Implications for Nigerian Companies.

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In today’s globalized economy, multinational corporations operating in Nigeria have become increasingly interconnected, engaging in cross-border transactions with their related entities. Transfer pricing, the pricing of these intercompany transactions, has been under scrutiny by tax authorities worldwide to prevent profit shifting and ensure a fair and equitable distribution of taxable income. In line with the global focus on transfer pricing, Nigeria has made significant strides in recent times with the introduction of new regulations and updates. This article delves into the recent developments in transfer pricing and their implications for Nigerian companies.

Recent Developments in Nigerian Transfer Pricing Regulations.

Nigeria’s Federal Inland Revenue Service (FIRS) has been proactive in aligning the country’s transfer pricing regulations with international standards, particularly the guidelines provided by the Organisation for Economic Co-operation and Development (OECD). Below are some of the recent key developments:

1. Transfer Pricing Documentation: Nigerian transfer pricing regulations now require multinational enterprises to prepare and maintain comprehensive transfer pricing documentation. The documentation should include a Master File, which provides an overview of the group’s global operations and transfer pricing policies, and a Local File, which contains specific information about the Nigerian entity’s related-party transactions.

2. Country-by-Country Reporting (CbCR): Nigerian constituent entities of multinational groups meeting certain revenue thresholds are now obligated to submit a Country-by-Country Report. This report provides tax authorities with crucial information on the global allocation of the group’s income, taxes paid, and other economic activities. CbCR enhances transparency and enables tax authorities to assess transfer pricing risks more effectively.

3. Advance Pricing Agreements (APAs): The FIRS now offers the option of entering into APAs with taxpayers. APAs provide a predetermined set of rules for calculating transfer prices, offering taxpayers certainty and reducing the risk of transfer pricing disputes. Nigerian companies engaging in complex intercompany transactions can benefit from seeking APAs to ensure compliance and minimize tax uncertainties.

4. Increased Transfer Pricing Audits: With an intensified focus on transfer pricing compliance, the FIRS has ramped up transfer pricing audits to assess related-party transactions thoroughly. Nigerian companies need to be well-prepared with proper documentation to withstand scrutiny during these audits.

Implications for Nigerian Companies.

The recent developments in transfer pricing regulations carry significant implications for Nigerian companies engaged in cross-border transactions with related parties:

1. Compliance Obligations: Nigerian companies must now prioritize transfer pricing compliance to meet the requirements of the revised regulations. Failure to do so can lead to substantial penalties, reputational damage, and prolonged tax audits.

2. Documentation Requirements: With the introduction of mandatory transfer pricing documentation, Nigerian companies must invest in gathering and maintaining accurate data, economic analysis, and relevant documentation to support their transfer pricing policies.

3. Risk of Transfer Pricing Adjustments: Heightened transfer pricing audits increase the risk of transfer pricing adjustments by tax authorities. Companies must ensure that their transfer pricing policies align with the arm’s length principle and are supported by robust documentation.

4. Opportunities for Certainty: While the increased focus on transfer pricing might seem daunting, companies can proactively seek APAs to achieve transfer pricing certainty and minimize the risk of future disputes.


As Nigeria aligns its transfer pricing regulations with international standards, it is crucial for Nigerian companies engaged in cross-border transactions to stay abreast of the recent developments. Compliance with the updated regulations and implementation of appropriate transfer pricing policies and documentation will not only ensure adherence to the law but also foster trust with tax authorities and strengthen the companies’ reputation.

Seeking professional guidance from experienced accounting and tax experts is essential for Nigerian businesses to navigate the complexities of transfer pricing regulations effectively. A proactive approach to transfer pricing compliance will enable companies to mitigate risks, enhance transparency, and focus on sustainable growth in the global market.

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.