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ARTICLE · 18 FEBRUARY 2025

Nigeria's Guidelines For Advance Pricing Agreements: A Giant Step In The Right Direction?

The Federal Inland Revenue Service (FIRS or "the Service") recently issued the keenly awaited Guidelines on Advance Pricing Agreements (APA) via Information Circular No. 2024/006 on 27 November 2024.

NigeriaTax
Akinwale Alao
Akinwale Alao

The Federal Inland Revenue Service (FIRS or "the Service") recently issued the keenly awaited Guidelines on Advance Pricing Agreements (APA) via Information Circular No. 2024/006 on 27 November 2024.

The Guidelines, which detail the process through which taxpayers can ensure a satisfactory level of certainty regarding the treatment of their related-party transactions, defines an APA as follows:

"... an arrangement between a taxpayer(s) and a tax administration that determines, in advance of controlled transactions, an appropriate set of criteria (e.g., transfer pricing methodology, comparables, and appropriate adjustments thereto, as well as critical assumptions as to future events) for the determination of the transfer price of those transactions that accords with the Arm's Length Principle over a fixed period based on the fulfilment of certain terms and conditions."

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