Check Point Ltd V FIRS: The Potential Implications For The Nigerian Transfer Pricing Regime

Since the introduction of Transfer Pricing (TP) Regulations in Nigeria, there have been some significant events which have shaped the TP landscape some of which include the introduction of the Income Tax (Country-by-Country Reporting) Regulations, 2018 [CbCR Regulations], the Income Tax (Transfer Pricing) Regulations, 2018 [2018 TP Regulations] and the first TP court case in Nigeria (Prime Plastichem vs the Federal Inland Revenue Service [FIRS]). These events were significant for various reasons including the introduction of TP specific administrative penalties, new, revised or updated provisions and in the Prime Plastichem case, the exhibition of the riskiness of TP audits and the potential for huge additional tax liabilities.