ARTICLE · 01 FEBRUARY 2019

Nigerian Transfer Pricing Outlook For 2019

Andersen in Nigeria

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The end of the year typically signals a winding down of activities by most firms. However December 2018 saw an unprecedented flurry of activities by Nigerian taxpayers to meet the 31 December deadline

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Andersen in Nigeria

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The end of the year typically signals a winding down of activities by most firms. However, December 2018 saw an unprecedented flurry of activities by Nigerian taxpayers to meet the 31 December deadline for fulfilling all pending Transfer Pricing (TP) compliance obligations, including filing of returns and submission of TP documentation.

This uncharacteristic behaviour was in response to the introduction of stiff penalties in the Income Tax (Transfer Pricing) Regulations, 2018 (the TP Regulations) published in August 2018 and the Federal Inland Revenue Service's (FIRS') public notice granting non-compliant taxpayers some form of amnesty to regularize their positions by 31st December 2018 or face the full force of the penalties. This significantly influenced the behaviour of taxpayers leading to increased compliance with the TP Regulations.

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