The Nigerian Transfer Pricing (TP) Regime has witnessed
significant developments in the last few years, which have resulted
in TP finally becoming one of the high-risk tax areas facing Group
Companies in Nigeria.
First, there was the introduction and implementation of the
Country-by-Country Reporting (CbCR) Regulations with significant
administrative penalties for non-compliance. The CbCR Regulations
ushered the Regime into an era of unprecedented transparency that
requires qualified Multinational Enterprises (MNEs) to disclose
their key financial information and economic activities in the
jurisdictions where they have footprints to tax authorities.
Second, the revised Nigeria TP Regulations (Revised Regulations)
released in 2018 also introduced steep administrative penalties for
non-compliance as well as some contentious provisions.
