The Nigerian transfer pricing (TP) rules have been published with a commencement date of 2 August 2012. It is effective for basis periods beginning after the commencement date. For example, a company with an accounting year end of 31 December will be required to have TP documentation in place for accounting periods commencing 1 January 2013 rather than 2012.
The regulations give effect to the existing anti avoidance provisions contained in the Personal Income Tax, the Companies Income Tax, and the Petroleum Profits Tax Acts. It aims, amongst others, to provide certainty in the tax treatment of related party transactions and will apply to both domestic and cross border transactions.