Transfer Pricing and the CIT Act: Compliance Requirements and Best Practices for Nigerian Businesses.


As global trade and cross-border transactions continue to grow, transfer pricing has become a critical area of concern for tax authorities worldwide. For Nigerian businesses engaged in international transactions with related parties, adherence to transfer pricing regulations is essential to ensure compliance with the Companies Income Tax (CIT) Act. As a leading accounting firm in Nigeria, we recognize the importance of transfer pricing compliance and offer insights into its requirements and best practices to assist Nigerian businesses in navigating this complex terrain.

Understanding Transfer Pricing:

Transfer pricing refers to the pricing of goods, services, or intangible assets exchanged between related parties, such as subsidiaries, affiliates, or branches of a multinational enterprise. The primary objective of transfer pricing regulations is to ensure that transactions between related parties are conducted at arm’s length, reflecting the market conditions that would exist between independent parties.

Compliance Requirements under the CIT Act:

  • Arm’s Length Principle: The CIT Act requires Nigerian businesses to use the arm’s length principle while determining transfer prices. This means that the prices applied in intercompany transactions must be comparable to what would have been charged between unrelated entities in similar transactions.
  • Documentation Requirements: Nigerian businesses engaged in related-party transactions must maintain detailed transfer pricing documentation to demonstrate compliance with the arm’s length principle. This documentation should include information on the economic analysis, methodologies used, and supporting data.
  • Penalty Provisions: Non-compliance with transfer pricing regulations can lead to penalties, interest charges, and potential reputational risks. It is essential for Nigerian businesses to adhere to the CIT Act’s transfer pricing requirements to avoid adverse consequences.

Best Practices for Transfer Pricing Compliance:

  • Conduct Transfer Pricing Studies: Nigerian businesses should conduct comprehensive transfer pricing studies to determine an appropriate transfer pricing methodology. Engaging experts in transfer pricing can help companies identify the most suitable method for their specific transactions.
  • Documentation Compliance: Maintaining accurate and up-to-date transfer pricing documentation is critical for compliance. Businesses should ensure that their documentation includes all relevant details, economic analyses, and supporting data.
  • Benchmarking Analysis: Benchmarking analysis involves comparing a company’s intercompany transactions with comparable transactions between unrelated parties. Nigerian businesses should perform benchmarking studies to ensure their transfer prices align with market conditions.
  • Advance Pricing Agreements (APAs): APAs are agreements between taxpayers and tax authorities that determine transfer prices in advance for a specified period. Entering into APAs with the Federal Inland Revenue Service (FIRS) can provide certainty and reduce the risk of transfer pricing disputes.
  • Professional Assistance: Given the complexities of transfer pricing regulations, Nigerian businesses should consider seeking professional assistance from accounting firms with expertise in international tax and transfer pricing.


Transfer pricing compliance is a vital aspect of the tax landscape for Nigerian businesses engaged in related-party transactions. By adhering to the arm’s length principle, maintaining comprehensive documentation, and implementing best practices, companies can mitigate the risk of non-compliance and associated penalties. Furthermore, professional assistance from reputable accounting firms can provide invaluable guidance and ensure that businesses navigate transfer pricing regulations with confidence.

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.