Transfer Pricing Documentation Requirements: Ensuring Compliance with Nigerian Regulations.

FIRS Issues New Transfer Pricing Regulations - Tax & Business Matters -  Nigeria


Transfer pricing, the practice of setting prices for transactions between related parties, has become a focal point for tax authorities worldwide. Nigeria, like many other countries, has implemented robust transfer pricing regulations to ensure that multinational enterprises conduct intercompany transactions at arm’s length and prevent tax evasion through profit shifting. One critical aspect of compliance with Nigerian transfer pricing regulations is the documentation requirement. In this article, we explore the essential aspects of transfer pricing documentation and its significance in ensuring compliance with Nigerian regulations.

The Importance of Transfer Pricing Documentation

Transfer pricing documentation is a comprehensive record of related-party transactions and the methods used to determine transfer prices. The documentation serves as evidence to demonstrate that the transactions are conducted at arm’s length, as if the parties were unrelated, and are in accordance with the arm’s length principle as defined by the Nigerian tax authorities.

The documentation requirement not only helps multinational enterprises fulfill their compliance obligations but also provides tax authorities with the necessary information to assess the appropriateness of transfer prices and identify potential tax base erosion and profit shifting.

Types of Transfer Pricing Documentation:

Under Nigerian transfer pricing regulations, taxpayers are required to prepare and maintain two primary types of transfer pricing documentation:

  • Master File: The Master File provides a comprehensive overview of the multinational group’s global operations, including its organizational structure, business activities, intangible assets, financial and tax positions, and transfer pricing policies. It helps tax authorities gain insights into the group’s overall transfer pricing practices and the allocation of profits among its entities.
  • Local File: The Local File contains specific information about the Nigerian entity’s related-party transactions. This includes details of the transactions, the transfer pricing methods used, a comparability analysis, and supporting data to justify the arm’s length nature of the prices.

Transfer Pricing Documentation Thresholds:

The Nigerian transfer pricing regulations apply to taxpayers meeting certain thresholds for related-party transactions. For the fiscal year, the thresholds for preparing and maintaining transfer pricing documentation are as follows:

  1. Total annual related-party transactions exceeding NGN 300 million for tangible goods, intangible assets, and services combined.
  2. Total annual related-party transactions exceeding NGN 50 million for management and administrative services only.

Contemporaneous Documentation Requirement:

One critical aspect of transfer pricing documentation in Nigeria is the “contemporaneous” requirement. Taxpayers must ensure that the documentation is prepared and available at the time of filing their tax returns. Contemporaneous documentation demonstrates that the transfer pricing policies were established before the related-party transactions occurred, ensuring that they are not retroactively adjusted to achieve a desired tax outcome.

Penalties for Non-Compliance:

Non-compliance with transfer pricing documentation requirements can lead to significant penalties. Nigerian taxpayers failing to meet the documentation obligations or submitting incomplete or inaccurate documentation may face transfer pricing adjustments, penalties, and interest on any adjustments made.

Ensuring Compliance with Nigerian Regulations:

To ensure compliance with Nigerian transfer pricing regulations and avoid potential penalties, businesses should consider the following:

  • Maintain Accurate Records: Keep detailed and accurate records of related-party transactions, including contractual agreements, pricing methodologies, and financial data.
  • Conduct a Comparability Analysis: Perform a thorough comparability analysis to justify the selection of the most appropriate transfer pricing method.
  • Seek Professional Guidance: Engage qualified accounting and tax experts with expertise in transfer pricing to assist in preparing comprehensive documentation and navigating the complexities of Nigerian transfer pricing regulations.


Transfer pricing documentation is a critical aspect of compliance with Nigerian regulations and provides a transparent record of related-party transactions. As tax authorities increasingly focus on transfer pricing to prevent profit shifting and tax avoidance, businesses must prioritize the preparation of robust documentation. By ensuring compliance with the documentation requirements, Nigerian companies can demonstrate their commitment to fair business practices and build trust with tax authorities while mitigating the risk of transfer pricing audits and penalties.

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.