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

Audit readiness in transfer pricing - Businessday NG


In today’s globalized business landscape, multinational companies often engage in transactions with their related parties, both within and outside Nigeria. However, these transactions must be conducted at arm’s length and reflect fair market value to prevent tax evasion and ensure a fair distribution of profits among jurisdictions. To address these concerns, the Company Income Tax (CIT) Act in Nigeria incorporates Transfer Pricing regulations. As an esteemed accounting firm, we aim to provide insights into transfer pricing compliance requirements and best practices under the CIT Act.

Understanding Transfer Pricing:

Transfer pricing refers to the pricing of goods, services, or intangible assets exchanged between related parties, such as a parent company and its subsidiary, within a multinational group. The objective of transfer pricing regulations is to ensure that transactions between related parties are conducted at arm’s length, replicating the pricing that would have occurred if the parties were independent and unconnected.

Compliance Requirements:

1. Arm’s Length Principle: Under the CIT Act, companies are required to determine the prices for transactions with related parties based on the arm’s length principle. This principle ensures that the pricing of transactions between related parties is consistent with the pricing of similar transactions between unrelated parties.

2. Documentation: Nigerian companies engaged in related party transactions are obligated to maintain transfer pricing documentation to demonstrate that their pricing complies with the arm’s length principle. The documentation must include detailed information on the selection of comparable transactions, pricing methodologies, and justifications for the pricing.

3. Compliance Threshold: The CIT Act stipulates a compliance threshold for transfer pricing documentation requirements. Companies must ensure that their related party transactions exceed the specified threshold before preparing and submitting transfer pricing documentation.

Best Practices for Transfer Pricing Compliance

1. Conduct Transfer Pricing Analysis: To ensure compliance, companies should conduct a thorough transfer pricing analysis, evaluating the arm’s length nature of their related party transactions. This analysis involves identifying comparable transactions and selecting appropriate transfer pricing methodologies.

2. Keep Up-to-date Records: Accurate and up-to-date records are crucial for transfer pricing compliance. Companies must maintain well-organized documentation to support their transfer pricing methodologies and demonstrate compliance with applicable regulations.

3. Seek Professional Advice: Transfer pricing rules can be complex, and regulations may vary based on industry and jurisdiction. Engaging the services of experienced transfer pricing specialists or accounting firms can provide valuable guidance and ensure accurate compliance.

4. Adopt Advance Pricing Agreements (APAs): An APA is a formal agreement between a taxpayer and the tax authority that establishes transfer pricing methodologies for a specific set of transactions over a predetermined period. Obtaining APAs provides certainty and reduces the risk of transfer pricing disputes.


Compliance with transfer pricing regulations is of utmost importance for companies operating in Nigeria engaged in related party transactions. Failure to comply can lead to tax assessments, penalties, and reputational damage. As a leading accounting firm, we stress the significance of adhering to the CIT Act’s transfer pricing requirements.

By conducting robust transfer pricing analysis, maintaining comprehensive documentation, and seeking professional advice, companies can ensure compliance, mitigate risks, and maintain a positive relationship with tax authorities. Adhering to transfer pricing best practices enhances transparency, fosters fair competition, and supports the Nigerian government’s efforts to combat tax evasion and promote economic growth.

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.