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Principles of Transfer Pricing.

VILT

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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