Principles of Transfer Pricing.


Prior to the enactment of Transfer Pricing Regulations in Nigeria in 2012 (the Regulations), the tax authorities in Nigeria had relied solely on the general anti-avoidance rules (GAAR) in the various Nigerian tax legislation to review intra-group arrangements.

The introduction of the Regulations provided a more structured regime for assessing affected transactions and combating mis-pricing of-intragroup commercial relationships and the attendant tax flight allegedly being suffered by Nigeria.

Similarly, multi- national companies appreciated the potential for relief from arbitrariness under the erstwhile regime.

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