One of the more common related party transactions conducted by
taxpayers in Nigeria is intra-group services. It has been observed
that Nigerian companies are net recipients of intra-group services
therefore creating significant outflow in the form of payments for
head office charges, shared services costs, management services
etc. It is therefore not surprising that this transaction has
become a transaction of interest to the Federal Inland Revenue
Service (FIRS).
The interest in intra-group service transactions is supported by
the inclusion of specific provisions on intra-group services in the
Income Tax (Transfer Pricing) Regulations, 2018 (the revised
Regulations). These provisions adopted some provisions included in
the 2017 OECD Transfer Pricing (TP) Guidelines (the OECD TP
Guidelines). The FIRS provided specific guidelines that must be
adhered to by taxpayers to demonstrate the substance of the
intra-group services and the appropriateness of the
