Nigeria – Transfer pricing forms, non-resident company tax returns

November 28: Nigeria’s Federal Inland Revenue Service previously indicated that it would no longer accept tax returns filed by non-resident companies on a “deemed profit basis,” but that non-resident companies must  file their tax returns on an “actual profit basis.”

These returns are to include audited financial statements as well as income tax computations, showing the taxable income, tax-deductible expenses, and capital allowances. The tax authority is expected to issue guidance that would specify the commencement date for filing on returns on an actual profit basis.

In addition to providing audited financial statements, non-resident companies must follow Nigeria’s transfer pricing regulations. The transfer pricing division of the Federal Inland Revenue Service indicated that non-resident companies must:

Complete and file the transfer pricing declaration and disclosure forms together with the tax returns

Prepare and submit the transfer pricing policies and contemporaneous documentation, when requested