Nigeria is one of the 31 countries that signed the Multilateral Competent Authority Agreement (MCAA) for implementing the exchange of country-by-country (CbC) reports. With this action, Nigeria will be entitled to receive CbC reports of multinational enterprises (MNEs) having their headquarters in one of the other MCAA partner countries. The CbC reports will include information such as a summary of income earned and tax paid, and the number of employees deployed by MNEs across the different jurisdictions of operation in a tax reporting period. The tax authorities then will be able to use the CbC reports to conduct certain transfer pricing, base erosion and profit shifting (BEPS)-related risk analysis, and other economic and statistical analyses.
Companies will be required in 2017 to submit CbC reports on “controlled transactions” conducting during the 2016 financial year. Also, it is most likely that Nigeria will provide rules that will facilitate the exchange of similar information with co-signatories. In any event, information—such as income earned and tax paid in different jurisdictions by MNEs that are operating in Nigeria—will be available whether or not similar legislation is passed in Nigeria.
The MCAA implementation is expected to put pressure on MNEs, especially those that have not properly documented and complied with Nigeria’s transfer pricing regulations with respect to the pricing of their related-party transactions. It will also be easier for the tax authority to identify and investigate MNEs that have actively engaged in BEPS-type transactions.
Read a February 2016 report [PDF 62 KB] prepared by the KPMG member firm in Nigeria
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