Transfer Pricing and International Transactions: Guidelines for Nigerian Companies.

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The globalization of business has brought about significant opportunities and challenges for Nigerian companies. As these firms increasingly engage in cross-border transactions within multinational enterprise (MNE) structures, it becomes crucial to address transfer pricing to ensure alignment with Nigerian tax laws and international standards. In this article, we will delve into the fundamentals of transfer pricing and provide guidelines for Nigerian companies to navigate the complexities of international transactions effectively.

The Growing Role of International Transactions:

International transactions encompass a wide range of activities, from importing and exporting goods to providing services, technology licensing, and financial dealings. Nigerian companies are venturing into these transactions to expand their markets, access resources, and tap into international expertise. However, international business activities raise transfer pricing concerns.

Understanding Transfer Pricing:

Transfer pricing is the method by which the prices for goods, services, or intangible assets are set between related entities within an MNE. The aim is to establish a fair market price for these transactions, as if they were conducted between unrelated parties.

Challenges in Transfer Pricing for International Transactions:

Nigerian companies engaging in international transactions may encounter various challenges when managing transfer pricing:

  1. Valuation Complexity: Determining the appropriate pricing for international transactions can be complex, particularly when valuing unique assets or services.
  2. Functional Analysis: A comprehensive functional analysis is necessary to identify and document the functions, assets, and risks associated with international business activities. This analysis forms the basis for determining the appropriateness of pricing.
  3. Comparability Analysis: Demonstrating that transfer pricing arrangements are consistent with what unrelated parties would agree to under similar circumstances can be challenging, as international transactions may differ significantly.
  4. Documentation Requirements: Adequate documentation of international transactions, including pricing methodologies, functional analyses, and any other information supporting transfer pricing decisions, is crucial to demonstrate compliance with transfer pricing regulations.

Guidelines for Effective Transfer Pricing Compliance:

To address these challenges and ensure effective transfer pricing compliance for international transactions, Nigerian companies should consider the following guidelines:

  1. Pricing Methodologies: Select appropriate transfer pricing methodologies, such as the comparable uncontrolled price method, the resale price method, or the transactional net margin method, based on the nature of the international transactions.
  2. Functional Analysis: Conduct a detailed functional analysis to identify and document the functions, assets, and risks associated with international business activities. Understand the value drivers specific to the services provided or assets transferred.
  3. Documentation: Maintain comprehensive documentation that outlines the terms of international transactions, transfer pricing methodologies, functional analyses, and any other information supporting transfer pricing decisions.
  4. Comparability Analysis: When conducting a comparability analysis, explore alternative data sources specific to international transactions, such as industry-specific benchmarks, market data, or expert reports.
  5. Advance Pricing Agreements (APAs): Consider negotiating APAs with Nigerian tax authorities to pre-determine the pricing of international transactions. APAs provide certainty and reduce the risk of disputes.


International transactions offer Nigerian companies significant opportunities for growth and market expansion. However, to ensure transparency, fairness, and compliance with transfer pricing regulations, it’s essential for these companies to prioritize transfer pricing considerations. By following the provided guidelines, including selecting appropriate pricing methodologies, conducting comprehensive functional and comparability analyses, maintaining detailed documentation, and considering APAs, Nigerian companies can effectively manage transfer pricing complexities in international transactions.

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.