Transfer pricing in Nigeria

Transfer pricing in Nigeria at a glance

Regulation Type National regulations
Are there specific transfer pricing regulations? Yes
Submission deadline Contemporaneously
Submission deadline upon request 21 days
Annual update required Yes
Official language requirements English
Potential impact of penalties N/A


Nigerian tax law

Rules for transfer pricing in Nigeria are based upon:

  • Income Tax regulation No 1, 2012


Rules for transfer pricing in Nigeria are generally in line with the OECD Transfer Pricing Guidelines. However, in the case of a conflict with the national regulations, the national regulations prevail.


Accepted methods

Accepted methods are:

  • the comparable uncontrolled price method
  • the resale price method
  • the cost plus method
  • the profit split method
  • the transactional net margin method
  • any other method that will lead to an arm’s length remuneration

Priority of methods

Rules for transfer pricing in Nigeria prescribe that a taxpayers should use the most appropriate method.

Documentation requirements

Information that should be included in the documentation:

  • Information about the group structure
  • Information about the groups business activities
  • Details of related party transactions
  • The pricing method adopted
  • Reasons for selecting the used method
  • Information on comparable transactions between unrelated parties.


Rules for transfer pricing in Nigeria prescribe that all documentation should be submitted in English.

Requirements to prepare documentation annually

In Nigeria transfer pricing documentation that related party transactions should be declared annually together with the annual tax return.

Submission deadline upon request by tax authorities

Upon request of the tax authorities, a taxpayers has 21 days to submit its documentation.

Advance Pricing Agreements


Transfer pricing regulations in Nigeria prescribe for the possibility to obtain unilateral, bilateral en multilateral Advance Pricing Agreements (APA).


Rules for transfer pricing in Nigeria state that APA’s can be obtained for a period that may not exceed three years.


In Nigeria no specific transfer pricing penalties are in place, meaning that ordinary tax penalties apply. | the global transfer pricing reference guide