Transfer Pricing Risk Assessment: Identifying and Mitigating Transfer Pricing Risks in Nigeria.


As international business transactions continue to grow in complexity, transfer pricing has become a critical area of focus for tax authorities around the world, including Nigeria. The Nigerian government is actively seeking to ensure that multinational enterprises (MNEs) conduct intercompany transactions in compliance with the arm’s length principle and that profits are fairly allocated among related entities. A comprehensive transfer pricing risk assessment is essential for businesses to identify potential risks and implement effective strategies to mitigate them. In this article, we explore the significance of transfer pricing risk assessment in Nigeria and how businesses can safeguard their operations and reputations.

Understanding Transfer Pricing Risks:

Transfer pricing risks arise when there is a possibility that related-party transactions are not conducted at arm’s length, leading to an inappropriate allocation of profits and potential tax challenges. Some of the common transfer pricing risks that businesses may encounter include:

  • Insufficient Documentation: Lack of proper transfer pricing documentation supporting the arm’s length nature of transactions can be a significant risk during tax audits.
  • Inaccurate Method Selection: Using inappropriate transfer pricing methods or inconsistent methods across transactions can lead to compliance issues.
  • Comparability Challenges: Difficulty in finding reliable comparable transactions for the functional and risk analysis can affect the determination of an arm’s length price.
  • Profit Shifting: Aggressive transfer pricing practices aimed at shifting profits to low-tax jurisdictions can attract scrutiny from tax authorities.

Importance of Transfer Pricing Risk Assessment

Conducting a thorough transfer pricing risk assessment is crucial for Nigerian businesses for the following reasons:

  • Compliance with Regulations: Identifying and addressing transfer pricing risks ensures that businesses comply with Nigerian transfer pricing regulations and the arm’s length principle.
  • Mitigation of Tax Controversies: A proactive risk assessment helps businesses reduce the risk of transfer pricing disputes and associated penalties.
  • Enhanced Business Efficiency: Implementing sound transfer pricing practices based on the risk assessment improves overall business efficiency and credibility.

Steps in Transfer Pricing Risk Assessment

A well-structured transfer pricing risk assessment involves the following key steps:

  • Data Collection: Gather relevant data on related-party transactions, including financial and operational information.
  • Functional and Risk Analysis: Analyze the functions performed, risks assumed, and assets used by each related entity involved in the transactions.
  • Comparable Analysis: Identify comparable transactions to determine whether the arm’s length standard is met.
  • Risk Identification: Identify potential transfer pricing risks based on the analysis conducted.
  • Risk Rating and Prioritization: Rate and prioritize risks based on their potential impact on the business.
  • Mitigation Strategies: Develop strategies to address and mitigate identified transfer pricing risks.

Mitigation Strategies for Transfer Pricing Risks

To mitigate transfer pricing risks in Nigeria, businesses can consider implementing the following strategies:

  • Comprehensive Documentation: Maintain proper and contemporaneous transfer pricing documentation to support the arm’s length nature of related-party transactions.
  • Advance Pricing Agreements (APAs): Seek APAs with the Nigerian tax authorities to gain certainty and protection from future transfer pricing disputes.
  • Benchmarking Studies: Regularly conduct benchmarking studies to ensure that transfer prices align with market conditions and industry standards.
  • Expert Guidance: Engage experienced accounting and tax experts to assist with transfer pricing risk assessment, compliance, and planning.


A robust transfer pricing risk assessment is essential for Nigerian businesses to navigate the complexities of transfer pricing regulations and mitigate potential risks. By proactively identifying and addressing transfer pricing risks, businesses can enhance their compliance efforts, foster trust with tax authorities, and optimize their cross-border operations.

As transfer pricing regulations continue to evolve, seeking professional guidance from accounting and tax experts with expertise in transfer pricing and Nigerian regulations is paramount. By working closely with qualified professionals, businesses can establish sound transfer pricing practices that align with regulatory requirements and contribute to their long-term success in the global marketplace.

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.