Transfer Pricing Documentation Review: Ensuring Adequate Documentation for Nigerian Tax Authorities.

Transfer Pricing – TAXSPEED


As Nigerian businesses expand their global reach and engage in cross-border transactions, transfer pricing documentation has gained paramount importance. Adequate documentation is not only a compliance requirement but also a means to demonstrate the arm’s length nature of transactions to tax authorities. In Nigeria, where transfer pricing regulations are becoming more stringent, a comprehensive transfer pricing documentation review is essential to ensure that companies are well-prepared to address inquiries from the tax authorities. In this article, we will explore the significance of transfer pricing documentation review and its role in ensuring compliance for Nigerian companies.

Transfer Pricing Documentation: A Compliance Imperative:

Transfer pricing documentation serves as a record of the analysis, methodologies, and data used to determine the arm’s length prices of transactions between related entities. Proper documentation is crucial for substantiating the accuracy of transfer pricing arrangements, fostering transparency, and mitigating potential tax disputes.

In Nigeria, transfer pricing documentation is required to be contemporaneous, meaning it should be prepared before the tax return is filed. This emphasizes the proactive approach Nigerian businesses must take to ensure their documentation is comprehensive and accurate.

Importance of Transfer Pricing Documentation Review:

A thorough transfer pricing documentation review provides several benefits for Nigerian companies:

  • Risk Mitigation: A robust documentation review helps identify any inconsistencies, gaps, or inaccuracies in the documentation, allowing businesses to rectify issues before they attract the attention of tax authorities.
  • Compliance Assurance: A well-executed documentation review ensures that the documentation is compliant with Nigerian regulations and follows international transfer pricing standards.
  • Efficient Tax Audits: In the event of a tax audit, having well-prepared documentation streamlines the process, reducing the time and resources required to respond to tax authority inquiries.
  • Demonstrating Good Faith: An up-to-date and comprehensive transfer pricing documentation review demonstrates a company’s commitment to compliance and transparent business practices.

Key Components of a Transfer Pricing Documentation Review:

A comprehensive transfer pricing documentation review includes the following components:

  • Functional Analysis: Ensure that the functional profiles, risks, and contributions of entities involved in the transactions are accurately captured.
  • Transfer Pricing Methods: Review the chosen transfer pricing methods to ensure they are appropriate and supported by reliable data.
  • Comparable Analysis: Verify the selection of comparables and assess whether they are truly comparable to the controlled transactions.
  • Economic Analysis: Review the economic analysis to ensure that it is consistent and accurately reflects the arm’s length pricing of transactions.
  • Documentation Organization: Verify that the documentation is organized, well-structured, and clearly explains the methodologies and analyses used.

Professional Assistance and Expertise:

Given the complexity of transfer pricing regulations and the technical nature of documentation review, Nigerian companies are advised to seek professional assistance from accounting and tax experts with expertise in transfer pricing.


A comprehensive transfer pricing documentation review is essential for Nigerian businesses engaging in cross-border transactions. By proactively ensuring the accuracy, completeness, and compliance of their documentation, companies can effectively mitigate transfer pricing risks, demonstrate transparency, and position themselves favorably in the event of tax authority inquiries.

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.