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

Transfer pricing documentation - TaxCoach


In Nigeria, as in many countries, tax authorities are becoming increasingly vigilant in enforcing transfer pricing regulations. As a result, it is imperative for Nigerian businesses engaged in cross-border transactions to maintain comprehensive transfer pricing documentation. However, it’s not just about creating this documentation; it’s also about ensuring that it is accurate, up-to-date, and compliant with Nigerian regulations. In this article, we will delve into the importance of transfer pricing documentation review and how it helps businesses maintain compliance with Nigerian tax authorities.

The Significance of Transfer Pricing Documentation:

Transfer pricing documentation serves as a vital tool for businesses to substantiate that their related-party transactions comply with the arm’s length principle. Proper documentation includes detailed records of the transactions, analyses, and methodologies used to determine pricing. This documentation is not only a compliance requirement but also a means of demonstrating transparency and preventing disputes with tax authorities.

Why Review Transfer Pricing Documentation?

Periodic review of transfer pricing documentation is essential for several reasons:

  1. Regulatory Changes: Tax regulations and transfer pricing guidelines can change over time. Regular reviews ensure that the documentation remains aligned with current regulations.
  2. Business Changes: Businesses evolve. Mergers, acquisitions, restructuring, or changes in business models can impact transfer pricing arrangements. Documentation should reflect these changes accurately.
  3. Audits and Disputes: In the event of a tax audit or dispute, thorough and updated documentation can be the key to a successful defense.
  4. Advance Pricing Agreements (APAs): If a business has an APA in place with Nigerian tax authorities, it is crucial to ensure that the documentation adheres to the terms of the agreement.

Elements of a Comprehensive Review:

When reviewing transfer pricing documentation for compliance, businesses should consider the following elements:

  1. Functional Analysis: Ensure that the functional analysis accurately reflects the roles, functions, and risks of the related entities involved in the transactions.
  2. Pricing Methodologies: Confirm that the pricing methodologies used are appropriate and in line with Nigerian regulations.
  3. Comparable Data: Review the selection of comparable data and ensure that it remains relevant and accurate.
  4. Financial Information: Verify that financial information, including profit and loss statements, balance sheets, and cash flow statements, is accurate and up-to-date.
  5. Local File and Master File: For businesses meeting specific thresholds, ensure that both the local file and master file are complete and consistent with each other.

Challenges and Solutions:

Reviewing transfer pricing documentation can present challenges:

  1. Complexity: Documentation can be complex, especially for businesses with diverse operations and significant related-party transactions.
  2. Data Management: Maintaining accurate and comprehensive records can be demanding.

To overcome these challenges, Nigerian businesses can collaborate with accounting and tax professionals experienced in transfer pricing documentation review.

Seeking Professional Assistance:

Given the intricacies of transfer pricing documentation, seeking expert assistance is advisable:

  1. Transfer Pricing Experts: Collaborate with accounting and tax professionals specializing in transfer pricing documentation to ensure thorough and accurate reviews.
  2. Legal Counsel: Legal experts can provide insights into the legal aspects of transfer pricing documentation.


Regular review and maintenance of transfer pricing documentation are critical for Nigerian businesses engaged in cross-border transactions. Accurate, up-to-date, and compliant documentation not only supports transparency and compliance but also minimizes the risk of disputes with Nigerian tax authorities.

Professional assistance from accounting and tax experts experienced in transfer pricing documentation review can significantly enhance Nigerian businesses’ ability to maintain compliance, demonstrate transparency, and address any potential issues efficiently.

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.