Statutory law is the most common limitation to the application of legitimate expectation in tax cases.

It is not enough to simply set revenue collection targets and celebrate when they are met or exceeded. Taxation is not a game where the end justifies the means.

Nigeria’s startup ecosystem has established itself as one of the most dynamic in Africa. Despite global headwinds in venture capital markets, funding into African technology companies remained significant in 2024, with Partech reporting that US$3.2 billion was invested across the continent, much of it concentrated in Lagos, a city that now ranks among the leading global hubs for technology talent and entrepreneurial activity.

Transfer pricing has become a critical concern for multinational enterprises (MNEs) operating in Nigeria. The Federal Inland Revenue Service (FIRS) has intensified their focus on cross-border...

On 19 February 2020, the Nigerian Tax Appeal Tribunal (the "Tribunal"), sitting in Lagos delivered its first ever judgement on a transfer pricing (TP) dispute under Nigeria's Income Tax...

Transfer Pricing in Nigeria is governed by the Income Tax (Transfer Pricing) Regulations, 2018. The TPR provides that Related Party Transactions should be conducted in line with the arm's length principle and provides compliance ...

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 onducted by the tax authorities.

Nigeria's tax system is undergoing one of its most comprehensive reforms in decades. The Nigeria Tax Administration Act 2025 ("NTAA" or the "Act") represents a major step toward a more efficient, transparent, and technology-driven tax administration.

Advance Pricing Agreements (APAs) are currently being discussed by most transfer pricing practitioners in Nigeria.

President Bola Ahmed Tinubu signed the four tax bills into law on 26 June 2025. Two of the laws took effect from 26 June 2025 while the Nigeria Tax Act and the Nigeria Tax Administration Act will become effective on 1 January 2026.

In 2021, the Nigeria Transfer Pricing (TP) space was impacted by a number of domestic and international developments, which are expected to shape and influence the TP landscape in 2022.

Intra-group financing arrangement, particularly interest-bearing loan arrangements, have long been one of the foremost tax planning strategies adopted by multinational enterprises to shift profits from one jurisdiction to another. As a result, tax authorities globally tend to scrutinize these arrangements under transfer pricing rules to ensure that the terms of these transactions are at arm’s length.

Both the Nigeria Tax Act, 2025 and the Nigeria Tax Administration Act, 2025 (the "NTAA") became effective on 1st January, 2026.

Nigeria's tax landscape has transformed with the Nigeria Tax Act 2025 and Nigeria Tax Administration Act 2025, introducing a comprehensive framework for collective investment schemes. These reforms consolidate previously fragmented tax provisions, exempt dividends from authorised CISs, and create greater certainty for fund managers, trustees, and investors in Nigeria's capital markets.

The expansion of the West African regional market to foreign investors, and the search for emerging markets has led to a continuous increase in business mobility and cross border investments with Nigeria.

In December 2019, just as the country was seeking to take a break from the many unpleasant news headlines and enjoy the upcoming Christmas season, a shocking topic caught the nation's attention...

Tax planning and management refers to the processes and schemes by which taxpayers arrange their affairs and businesses in such manner as to attract the lowest possible tax rates under ...

Multinational Enterprises (MNEs) now operate beyond their countries of residence.

The Federal Government recorded a notable achievement on January 13th 2020 when President Buhari signed the Finance Act No. 1 of 2020 into law.

Recently, as part of LeLaw's Nigerian country chapter contribution to Bloomberg's Winter 2020/Spring 2021: Transfer Pricing Forum, (Bloomberg Publication), we used TP lenses to look closely at the...