Nigeria: Country-by-country reporting requirements by branches and subsidiaries of foreign MNEs

CbC filing obligations of Nigerian resident branches and subsidiaries of foreign MNEs

CbC filing obligations of Nigerian resident branches and subsidiaries of foreign MNEs

The Federal Inland Revenue Service (FIRS) on 4 January 2022 issued a notice withdrawing an earlier notice that had suspended the requirements for Nigerian resident branches and subsidiaries (constituent entities) of foreign multinational enterprises (MNEs) to file country-by-country (CbC) reports in Nigeria.

Read the January 2022 FIRS notice [PDF 139 KB]

The pertinent CbC regulation requires constituent entities of MNEs operating in Nigeria to submit a CbC report to the FIRS when there is no agreement for an automatic exchange of information between Nigeria and the country of residence of the ultimate parent entity (UPE). 

The FIRS in May 2021 issued a notice suspending CbC reporting obligations for branches and subsidiaries of MNEs operating in Nigeria. Read TaxNewsFlash

Therefore, with withdrawal of the suspension order, these constituent entities are expected to comply with the CbC filing requirement effective from 1 January 2022. 

KPMG observation

Withdrawal of the suspension order aligns with Nigeria’s change-in-status to a “reciprocal jurisdiction” following a review of its compliance with the confidentiality and data safeguard requirements and for submission of notifications for reciprocal exchanges of CbC reports.

Nigeria’s change-in-status to a reciprocal jurisdiction means that it can now receive CbC reports from the other 78 exchange partners under the Multilateral Competent Authority Agreement regarding the exchange of CbC reports.

Constituent entities whose UPEs are not residents in the jurisdictions of any of the listed exchange partners may, therefore, now have filing obligation in Nigeria. These taxpayers need to verify their status under the CbC regulations to comply with the law.  

Read a January 2022 report [PDF 195 KB] prepared by the KPMG member firm in Nigeria


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