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Nigeria: Insights into transfer pricing regulations, implications for MNEs

Nigeria: Insights into transfer pricing regulations

Nigeria’s Federal Inland Revenue Service in March 2018 released revised transfer pricing regulations that have implications for multinational entities (MNEs).


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Among the provisions in the transfer pricing regulations are:

  • New penalty measures for failures to comply with the transfer pricing rules
  • Information and documentation requirements relating to procurement arrangements involving related parties and intra-group services
  • A 5% limitation of EBITDA (earnings before interest, tax, depreciation and amortization) on the amount deductible for income tax purposes with regard to payments involving the transfer or rights of intangibles such as patents, trade secrets, and trademarks
  • Transfer pricing documentation rules including requirements for a Master file and a Local file
  • Clarification that only pricing arrangements approved by the tax authority (and not other government agencies) qualify for a safe harbor 
  • Measures concerning the dispute resolution process

Read a prior KPMG report about the new transfer pricing regulations: TaxNewsFlash-Transfer Pricing

Tax professionals with the KPMG member firm in Nigeria have further examined the changes introduced by the new transfer pricing regulations in a report that was published in the 2 October 2018 edition of Bloomberg BNA Daily Tax Report: International, and is available on Bloomberg BNA’s website:

Insight: Revised Transfer Pricing Regulations in Nigeria—Implications for MNEs


For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services practice in Nigeria:

Tayo Ogungbenro | +23 412 718 941 |

Victor Adegite | +23 412 718 955 |

Omojo Okwa | +23 412 718 955 |

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