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ARTICLE · 15 JANUARY 2025

FIRS Issues Guidelines On Advance Pricing Agreements In Nigeria

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In the evolving global tax landscape, related-party transactions and transfer pricing (TP) have become pivotal issues for tax authorities worldwide. Recognizing the complexities and potential disputes

NigeriaTax
Tayo Ogungbenro
Tayo Ogungbenro

In the evolving global tax landscape, related-party transactions and transfer pricing (TP) have become pivotal issues for tax authorities worldwide. Recognizing the complexities and potential disputes surroundingTP, the Federal Inland Revenue Service (FIRS) recently introduced comprehensive Guidelines on Advance Pricing Agreements (APAs) through Information Circular No. 2024/006, which was published on 27 November 2024 (hereafter referred to as "the Guidelines" or "the Circular").

The Guidelines have an effective date of 1 January 2025 and provide a structured framework for taxpayers to negotiate predetermined TP methodologies with the FIRS that would govern their proposed controlled transactions, thereby reducing uncertainties and fostering trust.

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