There are eight business days to the deadline for the statutory filing of country-by-country (CbC) reporting notification and the CbC report for companies with a 31 December accounting year-end date.
Tax rules in Nigeria require Nigerian-headquartered multinational enterprise (MNE) groups with minimum consolidated revenue of ₦160 billion to file a CbC report with the Federal Inland Revenue Service (FIRS) within 12 months from the reporting accounting year-end of the company. Hence, for 2018 financial year, the CbC report is due by 31 December 2019.
Also, Nigerian resident members of MNE groups headquartered outside Nigeria are required to notify the FIRS of the identity and tax jurisdiction of the entity that will be responsible for filing the CbC report when the MNE group has a consolidated revenue of €750 million (or equivalent in the domestic currency of the jurisdiction of the ultimate parent entity or the surrogate parent entity). This notification is due by the last day of the reporting year-end of the group.
The rules also provide for a “secondary filing” of CbC reports in Nigeria. This applies to Nigerian members of MNE groups with ultimate parent entities in jurisdictions that do not have a qualifying competent authority agreement in place to allow for the automatic exchange of the group’s CbC report with Nigeria.
Failure to file the CbC report with the FIRS by the due date is subject to a penalty assessment.
Read a December 2019 report [PDF 125 KB] prepared by the KPMG member firm in Nigeria
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