Tax update · 5 Jul 2025 · 5 min read
Key takeaways
- Map all related-party flows: goods, services, royalties, management fees and loans.
- Align transfer pricing policy to how the business actually operates, not only to templates.
- Prepare local file support before FIRS requests it—not after an assessment letter arrives.
Why transfer pricing is on the agenda
Groups with cross-border or related-party transactions in Nigeria face increasing expectation that charges are arm's length and documented. Manufacturing, energy, financial services and tech platforms are common focus areas.
Directors should treat transfer pricing as a governance topic, not only a tax department task.
Building a defensible policy
Start with a transaction map: who sells what to whom, how prices are set, and which entities retain risk and reward.
Select methods appropriate to each transaction type and maintain contemporaneous support—contracts, benchmarking rationale and board approvals where material.
When to involve advisers
Before restructuring, entering new markets or after receiving FIRS correspondence, a focused diagnostic prevents expensive rework.
Our tax practice supports policy design, documentation and structured engagement with authorities.
General information only—not tax, legal, or investment advice. For guidance specific to your business, contact KACERTIFIEX under an engagement or discovery discussion.
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