Navigating Nigeria's Transfer Pricing Rules in 2024
Nigeria's Federal Inland Revenue Service has tightened its transfer pricing documentation requirements. Here's what multinational groups operating in Nigeria need to know to stay compliant and avoid penalties.
Transfer pricing remains one of the most scrutinised areas of tax compliance for multinationals operating across Africa. Nigeria's Federal Inland Revenue Service (FIRS) has progressively aligned its rules with the OECD Guidelines, and 2024 has brought a sharper enforcement posture.
What Has Changed
The FIRS Income Tax (Transfer Pricing) Regulations now require Country-by-Country Reporting (CbCR) for multinational enterprise groups with consolidated revenues above ₦160 billion. Groups that fall below this threshold must still maintain robust local file documentation demonstrating that intercompany transactions are conducted at arm's length.
Key Compliance Priorities
Groups should prioritise three areas: first, documenting the functional analysis of all related-party transactions; second, benchmarking intercompany pricing against comparable uncontrolled transactions; and third, ensuring that their master file and local file are current and filed within the stipulated deadlines.
The penalty for non-compliance is no longer just financial — FIRS has begun using transfer pricing audits as an entry point for broader tax investigations.
At GECA, our Tax Advisory practice assists clients with full transfer pricing documentation, dispute resolution with FIRS, and advance pricing agreements where applicable. Reach out to discuss how your group's structure can be optimised for both compliance and efficiency.