May 8, 2018
With the current review of the Nigeria Transfer Pricing (TP) Regulations (the Regulations) by the Federal Inland Revenue Service (FIRS) after over five years of its introduction, it is imperative that we critically review the contending issues pertaining to the current Regulations. This will enable all stakeholders better assess whether the revised version, when gazetted, has addressed these contending issues.
This article reviews the following contending issues:
One of the key barometers used in this review and to be used in assessing the revised version is whether the Regulations has provided certainty in the treatment of related party transactions. This objective is very critical if the Government, specifically the FIRS, wants to achieve significant increase in voluntary compliance with the Regulations.
Next, we will review each of the contending issues relating to the current Regulations by identifying the source of ambiguity, indicating our expectation of how the FIRS may address each issue, and providing our insights as to whether the anticipated FIRS approach will suffice in mitigating or better still eliminating the ambiguities identified.