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Transfer Pricing Country-by-Country Reporting

Transfer Pricing Country-by-Country Reporting

This publication gives a summary of the Federal Government of Nigeria's arrangement to shore up its commitment to International tax transparency by incorporating he country-by-country report into the TP regulations

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The Federal Government of Nigeria (FGN) has concluded arrangements to shore up the level of its commitment to international tax transparency by incorporating the Country-by-Country Report (CbCR) into the Transfer Pricing (TP) Regulations.


This will permit exchange of information among countries that have signed agreement on exchange of corporate information to prevent Base Erosion and Profits Shifting (BEPS). The proposed CbCR Regulations is expected to be in line with the model legislation issued by the Organization for Economic Cooperation and Development (OECD). The CbCR is one of the three-tiered TP documentation approach recommended by the OECD to address BEPS (Action 13). It requires multinational enterprises (MNEs) to provide information on revenue, profits, taxes, employees and other economic activities of the group per jurisdiction, using a standard template.

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