Transfer Pricing

Transfer Pricing (TP) AND OTHER CONTEMPORARY ISSUES

Transfer Pricing Regulations

Transfer pricing is a very important international tax issue facing Multinational Enterprises (MNEs). Transfer prices may affect the Group’s taxable income in the different countries in which it operates. Tax authorities of the various countries where the Group has presence are becoming more interested in transactions with related parties as they affect their tax revenue.

 Income Tax (Country by Country) Regulations

Country-by-country reporting (CbCr) aims to provide tax authorities with additional information on cross-border corporate structures. Generating country-based reports for multinational enterprises and automatic exchange of their information is meant to allow the tax authorities to better review them.

 Common Reporting Standard (CRS)

CRS is a set of rules for automatic exchange of financial account information between the tax authorities of countries that have opted to make such exchanges. The legal framework for CRS in Nigeria is Income Tax (Common Reporting Standard) Regulations, 2019, and the following Nigerian institutions are affected by the Regulations:

i. Banks

ii. Insurance companies

iii. Asset/Portfolio Managers; and

iv. Investment Funds/Trusts Companies

There are various legal frameworks and international conventions which businesses especially those having related party transactions need contend with to ensure compliance and avoid sanctions. Our Firm, Ijewere & Co. Is available to help you on matters concerning compliance with Transfer Pricing and the other related regulatory matters. We offer the following services:

i. Ensuring compliance with Transfer Pricing, CbCr and CRS guidelines,

ii. Providing guidance in planning and optimizing Transfer Pricing policies,

iii. Assisting with dispute resolution on matters relating to TP, CbCr and CRS compliance