Transfer Pricing Audits: The Need for Taxpayers to Proactively Prepare


Wednesday, November 19, 2020 / 10:00 AM / By Deloitte / Header Image Credit: Transfer Pricing Asia


The Federal Government of Nigeria has recently intensified efforts to shore up non-oil revenue in a bid to ease budgetary pressures. Non-oil tax revenue seems to be one of the "low-hanging fruits" and consequently, the Federal Inland Revenue Service (FIRS) has a mandate to explore options available to optimise tax revenue (under its administration), with a key focus on Transfer Pricing (TP).

The Income Tax (Transfer Pricing) Regulations, 2018 ("TP Regulations") among other things, provides guidance on TP compliance obligations and prescribes penalties for non-compliance.

The FIRS has been aggressive in enforcing the penalty provisions in the TP Regulations and some taxpayers have been penalised for various infractions. However, the revenue from administrative penalties is expected to reduce significantly over the next two years as a result of increased awareness of taxpayers with respect to their TP obligations.

Consequently, we expect the FIRS to redirect attention to TP audits in ensuring adherence to the TP Regulations.


The article Transfer Pricing Audits: The Need for Taxpayers to Proactively Prepare was first published in The Guardian Newspaper on 12th November 2020 and later re-published in Deloitte on 17th November 2020.


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