In Nigeria, country-by-country (CbC) reporting would be incorporated as part of the transfer pricing regulations. This, in turn, would permit the exchange of information among countries that have signed an agreement for the exchange of corporate information to prevent base erosion and profit shifting (BEPS).
The proposed CbC reporting rules in Nigeria are expected to be in line with the recommendations of the Organisation for Economic Cooperation and Development (OECD). The addition of CbC reporting rules in Nigeria would require the reporting of certain taxpayer information, including information about income derived from Nigerian activities (relative to global income) and the amount of taxes paid or accrued in each jurisdiction where a multinational enterprise (MNE) operates. This information would aid the ability of the Nigerian tax administration to assess taxpayer exposure to BEPS and transfer pricing risk.
Companies that have not performed appropriate studies concerning the arm’s length nature of their related-party transactions need to consider taking certain steps. Tax professionals believe that the exchange of CbC reports could increase the risk of tax audits and exposure to additional tax liability for MNEs operating in Nigeria. Affected taxpayers and MNEs need to consider reviewing their tax and accounting policies and records so as to identify and address potential transfer pricing risks.
Read a March 2018 report [PDF 154 KB] prepared by the KPMG member firm in Nigeria
© 2018 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.