The Nigeria Transfer Pricing Regulations (NTPR) 2018 include
various compliance obligations for taxpayers, one of which is the
filing of annual statutory Transfer Pricing (TP) returns with the
Federal Inland Revenue Service (FIRS).
While the requirement to file TP returns is not new as there
were provisions for this in the 2012 TP Regulations, there was
medium compliance by taxpayers due to the lack of TP specific
penalties. The introduction of steep administrative TP penalties
(minimum of ₦10 million) for failure to file TP returns in
the NTPR has made the filing of TP returns extremely important,
with taxpayers and tax consultants making every effort to prepare
and file TP returns before the deadline.
