Transfer Pricing Audits: What to Expect and How to Prepare in Nigeria.

Preparation for transfer pricing audit - TaxCoach


Transfer pricing, the pricing of transactions between related parties, is a critical area of focus for tax authorities in Nigeria. To ensure compliance with the arm’s length principle and prevent profit shifting, the Nigerian government conducts transfer pricing audits to assess the fairness of related-party transactions. For businesses engaged in cross-border operations, being prepared for a transfer pricing audit is essential to navigate the process successfully. In this article, we explore what Nigerian companies can expect during a transfer pricing audit and how to effectively prepare for it.

Understanding Transfer Pricing Audits:

Transfer pricing audits are comprehensive reviews conducted by the tax authorities to examine related-party transactions and assess whether they comply with the arm’s length principle. The primary objective of these audits is to ensure that taxable profits are accurately reported, and transfer prices are set at fair market values.

During a transfer pricing audit, the tax authorities scrutinize the transfer pricing documentation, conduct functional and risk analyses, and compare the transfer prices to independent comparable transactions to determine if any adjustments are necessary.

What to Expect During a Transfer Pricing Audit in Nigeria:

When a Nigerian business is selected for a transfer pricing audit, several steps and stages are involved:

  1. Notification: The business will receive a notice from the tax authorities informing them of the audit.
  2. Information Request: The tax authorities will request transfer pricing documentation, financial records, and other relevant data related to the audited transactions.
  3. Data Analysis: The tax authorities will analyze the submitted information, comparing it with independent industry data and economic indicators.
  4. Interviews and Discussions: The tax authorities may conduct interviews with key personnel to gain a deeper understanding of the business’s operations and transfer pricing practices.
  5. Audit Report: Following the audit, the tax authorities will issue an audit report outlining their findings and any potential transfer pricing adjustments.

How to Prepare for a Transfer Pricing Audit in Nigeria:

Being adequately prepared for a transfer pricing audit can significantly impact the audit’s outcome and ensure a smooth process. Nigerian companies can take the following steps to prepare effectively:

  1. Maintain Comprehensive Documentation: Ensure that all transfer pricing documentation is complete, accurate, and up-to-date. This includes maintaining contemporaneous documentation that supports the arm’s length nature of related-party transactions.
  2. Conduct Internal Reviews: Conduct regular internal reviews of transfer pricing policies and practices to identify any potential issues or discrepancies.
  3. Engage Professional Experts: Seek assistance from experienced accounting and tax experts with expertise in transfer pricing to help prepare the necessary documentation and navigate the audit process.
  4. Address Identified Risks: Address any identified transfer pricing risks proactively before the audit to minimize potential adjustments.
  5. Stay Informed: Stay updated with the latest transfer pricing regulations and guidelines to ensure compliance with Nigerian requirements.


Transfer pricing audits are a part of the Nigerian tax authorities’ efforts to ensure that multinational enterprises conduct related-party transactions fairly and transparently. Being prepared for a transfer pricing audit is crucial for Nigerian businesses to navigate the process successfully and demonstrate compliance with the arm’s length principle.

By maintaining comprehensive transfer pricing documentation, conducting internal reviews, seeking professional guidance, and staying informed about regulatory developments, Nigerian companies can approach transfer pricing audits with confidence and minimize the risk of potential tax adjustments.

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.