Nigeria: Suspended country-by-country reporting requirements for MNE branches and subsidiaries

A notice regarding the suspension of the CbC reporting obligations of MNE branches and subsidiaries

Suspension of the CbC reporting filing obligations of MNE branches and subsidiaries

The Federal Inland Revenue Service (FIRS) issued a notice suspending country-by-country (CbC) reporting obligations for branches and subsidiaries of multinational enterprises (MNEs) operating in Nigeria.

Regulation 4 of the “Income Tax (Country-by-Country (CbC) Reporting) Regulations, 2018” requires branches and subsidiaries of MNEs operating in Nigeria to submit their CbC reports to the FIRS when there is no automatic exchange of information mechanism existing between Nigeria and the country of residence of the “ultimate parent entity“ (UPE). 

Therefore, with suspension of Regulation 4, MNE branches and subsidiaries are not required to submit the CbC reporting information to the FIRS. 

However, the suspension of Regulation 4 does not affect members of MNEs whose UPE or surrogate parent entity is a resident of Nigeria; these entities must still file CbC reports in Nigeria. The suspension also does not excuse all relevant entities from continued compliance with other obligations—including the filing of an annual CbC notification.

KPMG observation

The suspension of the CbC report filing obligations of MNE branches and subsidiaries is aligned with Nigeria’s current status as a “non-reciprocal jurisdiction.” Currently, Nigeria provides CbC reports to the 61 exchange partners under the Multilateral Competent Authority Agreement for the exchange of CbC reports, but Nigeria does not receive any CbC reports from its exchange partners due to Nigeria’s non-reciprocal jurisdiction status.

Read a May 2021 report [PDF 674 KB] prepared by the KPMG member firm in Nigeria



The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.