In recent years, transfer pricing (TP) has emerged as a significant concern for multinational enterprises (MNEs) operating in Nigeria. With the Nigeria Revenue Service (NRS) (formerly Federal Inland Revenue Service) intensifying efforts to generate revenue through taxation, taxpayers face heightened scrutiny, prolonged audits, and increasing risk of double taxation.

On November 27, 2024, the Federal Inland Revenue Service (‘the FIRS or the Service") issued the Advance Pricing Agreement (APA) Guidelines (the Guidelines) through Information Circular No. 2024/006, with an effective date of 1 January 2025.

Taxpayers and tax administrators have continued to grapple with the burden of undertaking complex Transfer Pricing (TP) analyses in order to justify the arm's length principle.

It comes as no surprise that Nigerian entities are net recipients of intercompany loans from their related parties in other jurisdictions. Nigerian entities enter such financial...

One of the major changes in the Income Tax (Transfer Pricing) Regulations 2018 (NTPR) is the introduction of administrative penalties.

Since the introduction of Transfer Pricing (TP) Regulations in Nigeria, there have been some significant events which have shaped the TP landscape...

The Federal High Court (FHC or "the Court") Lagos Judicial Division has ruled, in the case between, BJ Pumping Services SA Panama (BJ Pumping or "the Company" or "the Appellant")...

The recent developments in the international taxation have significantly impacted Nigeria's Transfer Pricing (TP) landscape.

Management fees are a common feature of intra-group arrangements within multinational enterprises (MNEs), reflecting charges for services provided by a parent company or related entity to its subsidiaries. These services are typically designed to promote operational efficiency, ensure consistency in group-wide policies, and allow group entities to benefit from centralized expertise.

The amendments to section 27 will come as good news to many taxpayers. It will however be bad news or a mixed bag for some others. For now, the main casualties are taxpayers whose businesses are...

The transfer pricing regulations cover all transactions between ‘connected taxable persons' that could impact the profit or loss position of any of the parties...

In the last three (3) years, there has been a significant increase in the number of Transfer Pricing (TP) audits conducted by the Federal Inland Revenue Service (FIRS).

Nigeria has grappled with sustained inflationary pressures in recent years, exerting widespread effects across all sectors of the economy.

In 1993, the Federal Inland Revenue Service (FIRS) announced uniform basis and rate for taxation of income derived by Non-Resident Companies (NRCs)

Navigating the complexities of international trade law can be difficult for businesses, especially in the presence of constantly changing government regulations in countries.

June 30, 2022 would mark the fourth anniversary of filing transfer pricing (TP) returns under the revised Transfer Pricing (TP) Regulations, 2018 for taxpayers with a December 31 year end.

The Nigeria Transfer Pricing Regulations 2018 include various compliance obligations for taxpayers, one of which is the filing of annual statutory Transfer Pricing returns with the Federal Inland Revenue Service.

Conducting business in Nigeria may present a range of complexities, particularly for companies engaged in cross-border transactions.

On Friday, September 27, 2019, the Tax Appeal Tribunal, Lagos Zone ("TAT" or the "Tribunal") held, inter alia, that where the action of a tax authority purports to make an assessment final and conclusive.

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.