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Nigeria: New transfer pricing regulations effective retroactively, March 2018

Nigeria: New transfer pricing regulations

The Federal Inland Revenue Service issued new transfer pricing regulations with a retroactive effective date from 12 March 2018. The new transfer pricing regulations replace regulations from 2012.


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Among the changes in the new transfer pricing regulations are the following:

  • Stricter penalties for non-compliance
  • New rules for documentation
  • Restricted application of a safe harbour 
  • A new definition of the term "connected persons"
  • A definition of "capital-rich-low-function companies"
  • Intra-group services and intangibles, pursuant to the OECD Transfer Pricing Guidelines
  • Transfer pricing documentation, a new threshold amount for maintaining contemporaneous documentation
  • Filing of updated transfer pricing declaration due within six months of the end of the accounting year
  • Amendments to the dispute resolution mechanism


Read an August 2018 report [PDF 795 KB] prepared by the KPMG member firm in Nigeria

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