Transfer Pricing Methods: Choosing the Appropriate Methodology for Nigerian Transactions.

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In the complex world of international business, transfer pricing plays a crucial role in determining the prices of goods, services, and intangible assets exchanged between related parties. To comply with Nigerian regulations and ensure fairness in cross-border transactions, multinational enterprises must employ appropriate transfer pricing methods. Selecting the right methodology is essential for demonstrating compliance with the arm’s length principle and avoiding potential tax disputes. In this article, we explore various transfer pricing methods and how Nigerian companies can choose the most suitable approach for their transactions.

Understanding Transfer Pricing Methods

Transfer pricing methods are analytical techniques used to establish the arm’s length price of transactions between related parties. The Organisation for Economic Co-operation and Development (OECD) and Nigerian transfer pricing regulations recognize several methods, each with its strengths and limitations. The choice of the method depends on the availability of reliable data and the nature of the transaction.

1. Comparable Uncontrolled Price (CUP) Method:

The CUP method compares the price of a product or service in a related-party transaction with the price of a similar product or service in an unrelated party transaction. This method is preferred when reliable data on comparable transactions are available.

2. Resale Price Method (RPM):

The RPM compares the gross profit margin earned by a reseller in a related-party transaction with the gross profit margin earned by an independent reseller in a comparable transaction. This method is suitable for situations where a company purchases goods from a related party and resells them to independent customers.

3. Cost Plus Method (CPM):

The CPM involves adding an appropriate markup to the cost incurred by a related party in providing goods, services, or intangible property to another related party. This method is commonly used when providing routine or contract manufacturing services.

4. Transactional Net Margin Method (TNMM):

The TNMM compares the net profit margin earned in a related-party transaction with the net profit margin realized in a comparable transaction between unrelated parties. This method is suitable for a wide range of transactions and is often used for routine services.

5. Profit Split Method (PSM):

The PSM allocates the combined profits of related parties involved in a controlled transaction based on their relative contributions to the value creation. This method is applied when it is challenging to separate the individual contributions of each party.

Selecting the Appropriate Transfer Pricing Methodology

Choosing the most appropriate transfer pricing method for Nigerian transactions requires a thorough understanding of the transaction’s characteristics and the availability of reliable data. Here are some considerations to guide Nigerian companies in making the right choice:

  • Availability of Data: The availability of reliable data is crucial in selecting a transfer pricing method. The chosen method should be based on data from comparable transactions to ensure accuracy and compliance.
  • Nature of Transactions: Different transfer pricing methods are suitable for different types of transactions. Consider the specific nature of the transaction to determine which method aligns best with its characteristics.
  • Functional and Risk Analysis: Conduct a detailed functional and risk analysis to understand the contribution of each entity involved in the transaction. This analysis will help identify the most appropriate method based on the value-added by each party.
  • Consistency: Ensure consistency in the application of transfer pricing methods across related-party transactions to avoid potential disputes with tax authorities.


Navigating transfer pricing methods can be complex for Nigerian companies engaged in international transactions. The key to successful compliance lies in selecting the most appropriate methodology for each transaction. By understanding the nuances of each method and seeking professional advice from experienced accounting and tax experts, Nigerian businesses can ensure compliance with transfer pricing regulations, mitigate tax risks, and foster transparent and fair international business practices.

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.