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Tax Alert
This alert contains:
FIRS releases Guidelines on Advance Pricing Agreements (APA)
Background
On 27 November 2024, the Federal Inland Revenue Service (FIRS) issued the Guidelines on Advance Pricing Agreements (APA).
The Guidelines give effect to the APA provisions of the Income Tax (Transfer Pricing) Regulations, 2018 and specify the procedures and conditions for taxpayers to obtain APAs in Nigeria. The Guidelines also stipulate the processes for the administration of executed APAs.
The Guidelines will take effect from 1 January 2025. We have summarised some of the key highlights of the Guidelines below.
Cost of application:
To apply for an APA, a taxpayer must make a nonrefundable deposit of $20,000 to the FIRS.
This payment will only be due after the FIRS has accepted the taxpayer’s APA proposal into the APA program. For APA renewals, the non-refundable deposit is $5,000.
Taxpayers will be responsible for all costs incurred by the FIRS (in excess of the non-refundable deposit) in processing an APA application. These include fees for engaging technical experts, travel costs for field visits, and other expenses.
Read the tax alert for the full report.
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