Transfer pricing has become a critical concern for multinational
enterprises (MNEs) operating in Nigeria. The Federal Inland Revenue
Service (FIRS) has intensified their focus on cross-border
transactions; hence, it is essential for companies to go beyond
merely following guidelines guiding Transfer Pricing in Nigeria and
setting up measures and controls aimed at proactively mitigating
transfer pricing risks. This article aims to provide insights and
strategies for taxpayers, particularly MNEs, in navigating the
complex landscape of transfer pricing in Nigeria.
The Income Tax Transfer Pricing Regulation introduced in 2012
and revised in 2018 was introduced to cater to how transactions
between two or more companies who are related by shares, control,
or ownership etc are conducted. This regulation was also set up to
serve as a localized and more practical guide of the Organization
for Economic Cooperation and Development (OECD) Transfer Pricing
Guidelines and is
