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Nigeria: Transfer pricing returns due 30 June, companies with 31 December year-end

Nigeria: Transfer pricing returns due 30 June

Companies with a 31 December year-end and required to file a transfer pricing return need to complete that filing requirement by the 30 June 2019 deadline.


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Under Nigerian rules—the Income Tax (Transfer Pricing) Regulations 2018—any company that has “connected persons” (related parties) must file its annual returns (that is, the transfer pricing declaration and disclosure forms) within six months after the date of the company’s accounting year-end. A failure to comply and file the transfer pricing returns by the due date may be subject to a penalty of ₦10 million in the first instance, and ₦10,000 for every day during which the failure continues. 

The Nigerian regulations permit companies that are unable to comply by the deadline to apply for an extension of time. The company must give its reasons for its inability to file a timely return.  The tax administration, however, has discretionary authority to accept or reject the application.  If rejected, the taxpayer will be deemed to have defaulted from the filing date when the return was due. 

To avoid imposition of a penalty, companies with connected persons need to comply with the requirements by 30 June 2019, whether or not the companies conducted a related-party transaction during the year ended 31 December 2018.  Any company that is unable to meet the deadline needs to consider applying for an extension of time before the 30 June deadline; follow up with the tax administration for approval; and then subsequently file the required returns within the extended period. 

Read a June 2019 report [PDF 167 KB] prepared by the KPMG member firm in Nigeria

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