Transfer Pricing and Customs Valuation: Strategies for Nigerian Importers and Exporters.

Customs determines import value of used clothing, shoes, leather products,  toys ‏ – Customs Today Newspaper


For Nigerian businesses engaged in international trade, the intersection of transfer pricing and customs valuation is an area of increasing importance. While transfer pricing focuses on setting the prices for transactions between related entities within a multinational enterprise (MNE), customs valuation determines the value of imported or exported goods for customs duty purposes. Harmonizing these two areas is crucial to ensure compliance with Nigerian regulations and optimize business operations. In this article, we will explore the strategies and considerations for Nigerian importers and exporters in managing transfer pricing and customs valuation.

Transfer Pricing and Customs Valuation: An Interplay

The relationship between transfer pricing and customs valuation arises when related entities within an MNE engage in cross-border transactions involving the exchange of goods. Here’s how they interact:

  1. Transfer Pricing and Export Prices: For Nigerian exporters, setting appropriate transfer prices for their goods is essential. The price at which goods are sold to foreign related entities affects the revenue and profitability of the Nigerian entity.
  2. Customs Valuation for Imports: When Nigerian importers bring goods from related foreign entities, customs authorities assess customs duties based on the value of the imported goods. This value should align with the arm’s length principle established in transfer pricing.

Strategies for Nigerian Importers and Exporters:

  1. Align Transfer Prices with Customs Valuation: It’s crucial to ensure that the prices used in transfer pricing for imported or exported goods are consistent with the customs valuation. Deviations can lead to customs disputes and penalties.
  2. Documentation is Key: Maintain comprehensive transfer pricing documentation that includes all relevant information on the pricing of goods. This documentation can be crucial in demonstrating compliance with both transfer pricing and customs valuation requirements.
  3. Use Appropriate Customs Valuation Methods: Familiarize yourself with the methods used for customs valuation in Nigeria, such as the transaction value method, and ensure that your pricing practices align with these methods.
  4. Advance Pricing Agreements (APAs): Consider entering into APAs with Nigerian tax authorities to establish the transfer pricing and customs valuation methodologies in advance, reducing the risk of disputes.
  5. Regular Reviews: Periodically review and update transfer pricing documentation and customs valuation practices to ensure they remain accurate and compliant with regulations.

Challenges and Solutions:

Nigerian importers and exporters may face challenges in managing transfer pricing and customs valuation:

  1. Data Availability: Obtaining accurate and reliable data for both transfer pricing and customs valuation can be challenging, especially for unique or specialized goods.
  2. Complex Transactions: Multinational enterprises often engage in complex transactions that require careful consideration of transfer pricing and customs valuation rules.

To address these challenges, consider seeking professional assistance from accounting and tax experts experienced in transfer pricing and customs valuation.

Seeking Professional Assistance:

Given the complexities and potential risks, it is advisable for Nigerian importers and exporters to seek expert assistance:

  1. Transfer Pricing and Customs Experts: Collaborate with accounting and tax professionals specializing in both transfer pricing and customs valuation to ensure compliance and accuracy.
  2. Legal Counsel: Legal experts can provide insights into the legal aspects of customs valuation and transfer pricing.


Harmonizing transfer pricing and customs valuation practices is essential for Nigerian importers and exporters. Accurate and compliant practices not only ensure smooth customs procedures but also support transparency and compliance with transfer pricing regulations.

By aligning transfer prices with customs valuations, maintaining comprehensive documentation, and seeking expert assistance, Nigerian businesses can navigate the complexities of these areas efficiently, reduce the risk of disputes, and optimize their international trade operations.

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.