Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 27 FEBRUARY 2025

Tax Reforms: Guidelines On Advance Pricing Agreements In Nigeria

Pavestones
Pavestones
Contributor
Pavestones

Pavestones

Pavestones is a client focused, solution driven and commercially savvy law practice, providing...

View firm profile
Explore more from Pavestones

On November 27, 2024, the Federal Inland Revenue Service (FIRS) issued the Guidelines on Advance Pricing Agreements ("the Guidelines") pursuant to Section 8(1)(u) of the FIRS...

NigeriaTax
Aderonke Alex-Adedipe
Aderonke Alex-Adedipe
Ebikeniye Best
Ebikeniye Best

Introduction

On November 27, 2024, the Federal Inland Revenue Service (FIRS) issued the Guidelines on Advance Pricing Agreements ("the Guidelines") pursuant to Section 8(1)(u) of the FIRS (Establishment) Act, 2007 and Regulation 9(12) of the Income Tax (Transfer Pricing) Regulations, 2018 to clarify the procedures and conditions for obtaining APAs, thereby enhancing tax compliance and reduce transfer pricing disputes.

In this newsletter, we have highlighted some of the key provisions of the Guidelines.

What is an Advance Pricing Agreement (APA)?

An APA is a formal agreement between a taxpayer and the tax authority that establishes the transfer pricing methodology, defines relevant comparables, and specifies any necessary adjustments for future transactions between the taxpayer and related parties. The purpose of the APA is to determine the transfer prices for future transactions in compliance with the Arm's Length Principle, for a fixed period1, based on

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

Nigeria Tax Reforms For Non-Residents: Expatriate & Foreign Company Guide

Nigeria's 2025 Tax Reform Acts introduce sweeping changes for non-residents, foreign investors, and expatriates operating in or deriving income from Nigeria. From expanded Permanent Establishment rules and Significant Economic Presence thresholds to mandatory VAT registration for offshore suppliers and Capital Gains Tax on indirect share transfers, the new framework fundamentally reshapes cross-border tax obligations. Understanding these provisions and taking proactive compliance steps is now essential for
NigeriaTax
Adeola Oyinlade & Co
Adeola Oyinlade & Co
Article

Examination Of The Value Added Tax Provisions Under The Nigeria Tax Act, 2025

On June 26, 2025, President Bola Ahmed Tinubu signed four transformative tax bills into law, fundamentally reshaping Nigeria's taxation landscape. The Nigeria Tax Act, 2025 repealed principal taxation legislations, introducing a comprehensive new framework that affects companies and taxpayers across the country. What are the key provisions of this new tax regime and how will it impact businesses operating in Nigeria?
NigeriaTax
Streamsowers & Köhn
Streamsowers & Köhn
Article

CBN’S Data Localisation Directive – Compliance Considerations For Payment System Participants

Nigeria's Central Bank has introduced sweeping data localisation requirements that will fundamentally reshape how payment service providers, banks, and financial institutions handle transaction data. With a January 2027 compliance deadline, these new rules mandate that all payment transaction data generated within Nigeria must be stored and managed locally, raising critical questions about cloud infrastructure, vendor relationships, and operational readiness. This analysis examines the scope of the requirem
NigeriaFinance and Banking
Pavestones
Pavestones
Article

Forex Trading In Nigeria: The Implications Of Sec Proposed Rules On Online Forex Trading For Technology And Platform Providers

Nigeria's Securities and Exchange Commission has proposed comprehensive rules for online Forex trading and Contracts for Difference (CFDs), establishing a regulatory framework that extends beyond brokers to encompass technology and platform providers. The proposed regulations introduce stringent capital requirements, operational standards, and compliance obligations for businesses providing trading infrastructure, raising critical questions about registration, data localization
NigeriaFinance and Banking
Pavestones
Pavestones
Article

Virtual Asset Service Provider (VASP) Licences In Kenya & Nigeria - What You Need To Know

Kenya and Nigeria are formalizing their digital asset markets through Virtual Asset Service Provider (VASP) licensing frameworks. While both countries require regulatory approval for crypto operations, their licensing categories, capital requirements, and compliance expectations differ significantly. Understanding these distinctions is essential for fintech founders and financial institutions seeking to enter or expand in these African markets.
NigeriaTechnology
Pavestones
Pavestones