In Nigeria, companies with related-party transactions may also have transfer pricing (TP) and country-by-country reporting (CbCR) responsibilities. These entities will file their TP and CbCR returns to the tax authority in the prescribed format. Thus far, the method of filing TP and CbCR returns has been a manual process. Taxpayers will soon say bye-bye to…
Recently, the Tax Appeal Tribunal affirmed that the additional liability of ₦1.74 billion on Prime Plastichem Nigeria Limited was legal. The decision in a transfer pricing dispute on 19 February 2020 between Prime Plastichem Nigeria Limited and FIRS (the Federal Inland Revenue Service). Federal Inland Revenue Service (FIRS or the tax authority) performed a TP…
The Federal Inland Revenue Service (FIRS) has started to enforce compliance with the Income Tax (Country-by-Country Reporting) Regulations (2018) in Nigeria. Under the Country-by-Country Reporting (CbCR) Regulations, multinational enterprises (MNEs) should provide the total details of income, tax paid, and economic activity in tax jurisdictions where the MNE conducts business. MNEs are also required to…
Here are four (4) facts on the latest public notice on Transfer Pricing (TP) regulations, 2018 issued by the Federal Inland Revenue Service on October 3, 2018. Is this the first TP regulation in Nigeria? Answer: No. It is a revised version of first TP regulation. The Income Tax (Transfer Pricing) Regulations (TP Regulations), 2018 replaces…
What is transfer pricing? We can split the term “transfer pricing” into two parts; “transfer” and “pricing”. Transfer means to move an item from one place to another. Pricing is the total money estimated or agreed in exchange for an item. Hence, transfer pricing is the amount which a company requires in payment for goods,…
Federal Inland Revenue Service (FIRS) has revised the Transfer Pricing Regulations in Nigeria. First, the new scope of Transfer Pricing Regulations (TPR) includes related or associated transactions based on the provisions of Capital Gains Tax (CGT) Act and Value Added Tax (VAT) Act. This means FIRS may scrutinise related party transactions for likely VAT and…