Transfer pricing (TP) describes the form of inter-company
pricing methods between two or more related economic entities with
respect to intra-group supply of goods, services, finance,
intellectual property, etc.
TP arrangement can be carried out between two or more related
organizations located in different countries (international
transfer pricing) or between 2 or more organizations carrying on
business within a country.
Enabling Legislation
TP is regulated by the Income Tax (Transfer Pricing)
Regulations, 20182 (TP Regulations) made pursuant to the
Federal Inland Revenue Service (Establishment) Act, 2007.3 The
objective of the TP Regulations, amongst others, is to ensure that
associated/related enterprises and companies pay tax on an
appropriate taxable basis corresponding to the economic activities
deployed by taxable persons in Nigeria. It aims to ensure that the
prices at which related entities exchange goods and services is in
conformity with the functions
