Transfer Pricing Awareness Survey

Transfer Pricing Awareness Survey

The Federal Inland Revenue Service (FIRS) published the revised Income Tax (Transfer Pricing) Regulations, 2018 (revised TP Regulations) in August 2018.


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Transfer Pricing Awareness Survey

The revised TP Regulations has an effective date of 12 March 2018 and applies to basis periods commencing on or after that date. With the introduction of the revised TP Regulations, it has become imperative for taxpayers to review their related party transactions to ensure that they align with the provisions of the Regulations. The objective of such review is to ensure full compliance and avoid TP adjustments or administrative penalties for non-compliance.

This TP survey was conducted in 2019 to determine the degree of taxpayers’ awareness of TP compliance requirements and TP risk assessment as well as gauge their TP audit experience. We are pleased to present the findings from the third edition of our survey. For this edition of the survey, we had 59 respondents, representing the major industry sectors.

Based on the feedback provided, we observed a significant improvement in the respondents’ level of compliance with the Regulations. Also, in respect of the Income Tax (Country-by- Country) Regulations, there is a high level of awareness and compliance as taxpayers in Nigeria are quickly embracing the changes in the ever evolving TP landscape. This may be as a result of the stringent administrative penalties imposed on defaulting taxpayers.

We hope that this edition of the survey will serve as a valuable reference material on TP from both the Nigerian and international perspectives. We also trust that our readers will find the results and insights provided useful in improving their organization’s TP compliance and audit experience.

We acknowledge and thank all the respondents that took out time to be a part of this year’s survey. We look forward to your participation in subsequent editions. We encourage our readers to provide feedback on the publication and participate in the subsequent editions of the survey. You can send your comments or indication of your interest to participate in future surveys by sending an email to

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