Transfer Pricing Regulations in Nigeria Finance Act 2022: Compliance and Best Practices.

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Transfer pricing has become a critical area of focus in international tax regulations, and Nigeria is no exception. The Nigeria Finance Act 2022 introduces significant updates to the country’s transfer pricing regulations, aiming to ensure fair and transparent pricing in transactions between related parties. In this article, we will delve into the key transfer pricing regulations in the Nigeria Finance Act 2022 and explore best practices for businesses to navigate this evolving landscape.

  • Transfer Pricing Documentation Requirements:

The Nigeria Finance Act 2022 places a strong emphasis on transfer pricing documentation. Multinational companies with related-party transactions are now required to prepare and maintain contemporaneous transfer pricing documentation. This documentation must support the arm’s length nature of their intercompany transactions.

Implication: Businesses engaging in related-party transactions should ensure that their transfer pricing documentation is comprehensive, accurate, and up-to-date to meet the new requirements.

  • Applicability of Transfer Pricing Methods:

The Act reaffirms the use of internationally recognized transfer pricing methods, such as the Comparable Uncontrolled Price (CUP) method, Resale Price method, Cost Plus method, and Transactional Net Margin method. However, the Act also introduces the possibility of using unspecified methods if the taxpayer can justify their application.

Implication: Businesses should carefully select and apply appropriate transfer pricing methods, ensuring they align with the economic substance of the related-party transactions.

  • Transfer Pricing Penalties:

To enforce compliance, the Nigeria Finance Act 2022 introduces penalties for non-compliance with transfer pricing regulations. Penalties may be imposed on taxpayers who fail to prepare and submit transfer pricing documentation within the stipulated timeframe or provide inaccurate information in their documentation.

Implication: Businesses should prioritize timely compliance with transfer pricing documentation requirements to avoid penalties and potential reputational risks.

  • Arm’s Length Principle:

The Act reinforces the arm’s length principle, which requires related parties to transact with each other as if they were unrelated parties dealing at arm’s length. The Act empowers the tax authorities to make adjustments to related-party transactions if they are not at arm’s length, thereby ensuring the appropriate tax base.

Implication: Businesses must conduct thorough benchmarking studies and demonstrate that their related-party transactions align with the arm’s length principle to avoid potential adjustments and disputes with the tax authorities.

  • Advance Pricing Agreements (APAs):

The Nigeria Finance Act 2022 recognizes the importance of Advance Pricing Agreements (APAs) as a means of providing certainty and avoiding transfer pricing disputes. Taxpayers can now enter into APAs with the Federal Inland Revenue Service (FIRS) to agree on transfer pricing methods and pricing arrangements in advance.

Implication: Businesses with complex or high-value related-party transactions should consider the benefits of entering into APAs to mitigate transfer pricing risks and provide clarity on their tax positions.


The Nigeria Finance Act 2022 brings a renewed focus on transfer pricing regulations, necessitating businesses engaged in related-party transactions to ensure compliance with the new provisions. With penalties for non-compliance and the importance of accurate transfer pricing documentation, businesses should adopt best practices in managing their transfer pricing affairs.

As a trusted accounting firm, we advise businesses to prioritize timely and accurate transfer pricing documentation, align related-party transactions with the arm’s length principle, and consider the benefits of Advance Pricing Agreements (APAs) to achieve certainty and minimize potential disputes. By doing so, businesses can navigate the complexities of transfer pricing regulations, demonstrate their commitment to compliance, and contribute to a fair and transparent tax environment in Nigeria.

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.