Wednesday, July 12, 2017 9:00AM /
The Organisation for Economic Cooperation and
Development (OECD), on 10 July 2017, released the revised edition of the
Transfer Pricing (TP) Guidelines for Multinational Enterprises and Tax
This 2017 edition of the TP Guidelines is an
update to the Guidelines issued in 2010. It mainly reflects a consolidation of
the changes resulting from the Base Erosion and Profits Shifting (BEPS)
Project. The revisions made to the Guidelines include;
revisions made in 2016 to reflect the clarifications and revisions agreed in
the 2015 BEPS Reports on Actions 8-10 “Aligning Transfer pricing Outcomes with
Value Creation” and on Action 13 “Transfer Pricing Documentation and
guidance on use of safe harbour rules approved in 2013 which recognises that
properly designed safe harbours can help to relieve some compliance burdens and
provide taxpayers with greater certainty
changes that were made to the rest of the OECD TP Guidelines to produce this
consolidated version of the Guidelines.
The 2017 revised OECD TP Guidelines retained
application of the “arm’s length principle” for valuation of cross-border
transactions between associated enterprises for income tax purposes. The
revised TP Guidelines take immediate effect in Nigeria as Nigeria’s TP
Regulations are required to be applied consistently with the OECD TP Guidelines
as amended or updated from time to time.
In the coming days, we will be bringing you a
detailed analysis of the changes contained in the 2017 revised TP Guidelines,
as well as their anticipated local impact in the Nigerian tax landscape.
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