• Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 11/4/2013

Nigeria - New transfer pricing forms, dedicated tax office 

November 4:  Nigeria’s Federal Inland Revenue Service (FIRS), in implementing the transfer pricing regulations issued in 2012, has released two transfer pricing forms—a transfer pricing declaration form and a transfer pricing disclosure form—and has established an office within the tax administration specifically to address transfer pricing issues.

Transfer pricing forms

Under Nigeria’s transfer pricing regulations (published in August 2012) taxpayers with related-party transactions must complete and file (1) a transfer pricing declaration form and (2) a transfer pricing disclosure form with their annual income tax returns.

The information requested in the transfer pricing declaration form and in the transfer pricing disclosure form is generally similar. However, there are some differences.

For instance, the transfer pricing declaration form requires taxpayers to disclose information concerning the parent corporation and the taxpayer’s directors.

The transfer pricing disclosure form requires taxpayers to provide information about their performance in relation to that of the group and to disclose information on goods and services provided for no consideration (including interest-free loans) to related parties.

Transfer pricing office

The FIRS created and launched the Transfer Pricing Division as an office within the tax administration that will implement the transfer pricing regulations (published in August 2012).

The new Transfer Pricing Division is physically located in the FIRS Building in Lagos.

KPMG observation

Tax professionals in Nigeria note that the FIRS’s actions in establishing the Transfer Pricing TP Division and in releasing the transfer pricing forms demonstrate the tax administration’s commitment to implement a robust transfer pricing regime in Nigeria. Because taxpayers need to have their transfer pricing policies in place for the 2013 financial year (including the need to file appropriate documentation), the window for action may fast be closing.

Read a November 2013 report [PDF 59 KB] prepared by the KPMG member firm in Nigeria: Transfer Pricing Division Constituted

Contact a tax professional with KPMG's Global Transfer Pricing Services.

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