Introduction
Transfer Pricing (TP) is fast becoming a stay awake issue for
Multinational Enterprises (MNEs) in Nigeria with the recent changes
in the TP landscape and the increased TP audits being conducted by
the tax authorities. To ensure better compliance among taxpayers
and provide clarity on certain TP issues, the Federal Inland
Revenue Service (FIRS) released the new TP Regulations which
imposes stiff penalties for non-compliance with TP rules.
Globally, there have been various developments in the TP space
with more countries having signed up to implement various
initiatives of the Organisation for Economic Co-operation and
Development's (OECD) Base Erosion and Profit Shifting (BEPS)
project. A number of these countries have enacted laws to tackle
harmful tax practices related to manipulative pricing of goods and
services for the purpose of BEPS.
