As the drive to increase government revenue continues in
Nigeria, taxes have taken a bigger role in generation of the income
to fund the budget. Transfer Pricing (TP) has not been left out, as
TP audits have become more common with the Federal Inland Revenue
Service attempting to conduct and conclude as many TP audits as
possible. Therefore, the possibility of a taxpayer being selected
for a TP audit has become significantly higher.
The increased probability of being selected for a TP audit
coupled with the technical nature of TP and the potential for huge
additional tax adjustments has made TP a major focus area for
taxpayers. Further, due to the varying interpretations of and
subjectivity in the application of TP concepts, the likelihood of
taxpayers ending up in a TP dispute with the tax authorities is
high. As such it is important that taxpayers take a proactive
approach to TP audits, having in mind the end game from the start
of the TP audit by evaluating the
