Transfer Pricing Audits by FIRS: Key Considerations and Compliance Requirements in Nigeria.

Tax Audit and Investigation – Niger State Internal Revenue Service


For multinational companies operating in Nigeria, transfer pricing is a critical area of tax compliance that requires meticulous attention. The Federal Inland Revenue Service (FIRS) actively scrutinizes transfer pricing practices to ensure that transactions between related parties are conducted at arm’s length and comply with transfer pricing regulations. In this article, we will explore key considerations and compliance requirements for Nigerian businesses facing transfer pricing audits by the FIRS.

Understanding Transfer Pricing:

Transfer pricing refers to the pricing of transactions between related parties, such as subsidiaries, affiliates, or companies under common control. These transactions can include the transfer of goods, services, intangible assets, or financing arrangements. The objective of transfer pricing regulations is to ensure that these transactions are conducted on terms that are comparable to those between unrelated parties, thereby preventing tax base erosion and profit shifting.

Key Considerations for Transfer Pricing Audits:

  • Compliance with Nigerian Transfer Pricing Regulations:

Nigerian transfer pricing regulations are in line with international best practices and the Organization for Economic Co-operation and Development (OECD) guidelines. Compliance with these regulations is crucial for businesses engaging in related-party transactions.

  • Arm’s Length Principle:

The arm’s length principle is the core foundation of transfer pricing. Transactions between related parties should be conducted as if they were unrelated, with prices and terms that would apply to independent entities in similar transactions.

  • Documentation and Reporting Requirements:

Taxpayers engaged in related-party transactions are required to maintain detailed transfer pricing documentation that supports the arm’s length nature of the transactions. This documentation should include functional and economic analyses, comparable data, and the selection of the appropriate transfer pricing method.

  • Transfer Pricing Methodology:

Selecting the most appropriate transfer pricing method is essential to ensure compliance. Nigerian regulations accept traditional methods such as the Comparable Uncontrolled Price (CUP) method, the Resale Price Method (RPM), the Cost Plus Method (CPM), and transactional profit methods.

  • Transfer Pricing Compliance Thresholds:

Nigeria has set specific transfer pricing compliance thresholds that determine which taxpayers are required to prepare and submit transfer pricing documentation. Taxpayers meeting these thresholds must comply with the documentation requirements and be prepared for potential transfer pricing audits.

Compliance Requirements for Transfer Pricing Audits:

  • Maintain Robust Documentation:

Taxpayers must maintain comprehensive transfer pricing documentation that supports the arm’s length nature of their related-party transactions. This documentation should be readily accessible in case of a transfer pricing audit.

  • Prepare a Transfer Pricing Study:

For companies with significant related-party transactions, preparing a transfer pricing study is essential. This study should provide an in-depth analysis of the company’s transfer pricing policies and demonstrate compliance with the arm’s length principle.

  • Seek Professional Advice:

Engaging experienced tax professionals or transfer pricing experts is highly recommended. They can provide valuable guidance in developing appropriate transfer pricing strategies, conducting transfer pricing studies, and ensuring compliance with Nigerian regulations.


Transfer pricing audits by the FIRS are becoming increasingly common as Nigeria intensifies its efforts to ensure tax compliance and prevent profit shifting. Nigerian businesses engaged in related-party transactions must proactively comply with transfer pricing regulations, maintain robust documentation, and implement appropriate transfer pricing methodologies. By staying informed about transfer pricing rules and seeking professional advice, businesses can mitigate the risk of transfer pricing disputes and penalties.

Remember, adherence to transfer pricing regulations not only fosters tax compliance but also strengthens the credibility and competitiveness of Nigerian businesses 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.