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
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