The year 2020 set in motion notable changes to the transfer pricing space that have had a profound impact on multinationals and local taxpayers alike. These changes include the implementation of the Finance Act, 2019; the release of the Significant Economic Presence Order, 2020; the Central Bank of Nigeria (CBN) directive on procurement companies; and the introduction of palliative measures to cushion the impact of COVID-19. With these changes comes a need for taxpayers to remain abreast of TP regulations to ensure full compliance and avoid administrative penalties for non-compliance.

This TP Survey was conducted in 2020 to determine the impact of COVID-19 on taxpayer’s businesses, assess their awareness of TP compliance requirements and TP risk assessment, and to gauge their TP audit experience. We are pleased to present to you our findings from the fourth edition of the survey.

Based on the feedback received from 46 respondents representing the major industry sectors, we observed a consistent level of compliance with the relevant TP regulations by the respondents as in the previous years. Also, in respect of the Income Tax (Country-by Country Reporting) Regulations, there is a high level of awareness and compliance as taxpayers in Nigeria are quickly embracing the changes in the ever-evolving TP landscape.This may be a result of the stringent administrative penalties imposed on defaulting taxpayers. We also note that most taxpayers have put measures in place to deal with the effects of COVID-19 with revenue and cashflows being the most affected aspects of their business operations. However, while a significant number of the respondents had neither ongoing nor completed TP audits, there has been an upsurge in the number of Information and Documents Requests (IDRs) (which generally precede a TP audit exercise) issued to taxpayers between the time when the survey was completed and published. This is due to recourse by the Federal Inland Revenue Service (FIRS) to TP audits as a mechanism to enforce compliance and increase revenue collection.

We hope that this edition of the survey will serve as a valuable reference material on TP from both Nigerian and international perspectives. We also trust that readers will find the results and insights provided useful as they seek to improve their organization’s TP compliance and audit experience.

We acknowledge and thank all the respondents that took out time to be part of this year’s survey. We look forward to your participation in subsequent editions. We encourage our readers to provide feedback to us on this publication and participate in the subsequent editions of the survey. You can send your comments or indicate your interest to participate in future surveys by email to

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