Table of Contents

COUNTRY-BY-COUNTRY REPORTING EXPLAINED

Introduction

Country-by-Country Reporting (CbCR) is a tax transparency framework introduced under the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13. It requires large multinational enterprise (MNE) groups to disclose, on an annual basis, how their income, taxes paid, and economic activities are distributed across every jurisdiction in which they operate.

Country-by-Country Reporting is not a financial statement or a transfer pricing study. It is a high-level risk assessment map for tax authorities. The CbC Report gives the Nigeria Revenue Service (NRS) and other tax authorities a snapshot of where an MNE group’s profits are booked, where its employees and assets are located, and whether there is a mismatch between economic substance and profit allocation.

For Nigerian MNEs and Nigerian entities of foreign-headed groups, CbCR compliance is now a mandatory annual obligation. The framework has recently undergone significant changes, with the Federal Inland Revenue Service (FIRS) migrating CbCR filings to the Automatic Exchange of Information (AEOI) Portal.

At Qeeva Advisory, we understand that CbCR compliance requires technical expertise, accurate data, and disciplined filing. Our team helps Nigerian MNEs and constituent entities navigate the CbCR framework, from threshold assessment through to portal filing.

This comprehensive guide explains Nigeria’s CbCR framework, who must file, what must be disclosed, the filing process, penalties for non-compliance, and how Qeeva Advisory helps businesses meet their obligations.

The Pain Points: Why CbCR Compliance Matters

The Transparency Imperative

CbCR is part of a global shift toward tax transparency. Tax authorities increasingly share information across borders through automatic exchange of information arrangements. The CbC Report gives the NRS a high-level map of where an MNE group’s profits are booked, where its employees and assets are located, and whether there is a mismatch between economic substance and profit allocation.

The Penalty Exposure

The penalties for CbCR non-compliance are severe. Late filing of the CbC Report attracts ₦10 million in the first instance, plus ₦1 million for each month the default continues. Failure to file the CbC Notification attracts ₦5 million in the first instance, plus ₦10,000 for each day of default.

The Dual-Platform Complexity

As at the 2024 reporting year, MNEs are required to file the CbC Notification on TaxPro-Max and the CbCR Notification and Report on the AEOI-CbCR Portal. This dual filing requirement adds complexity and increases the risk of missed deadlines.

The Data Challenge

The CbC Report requires detailed financial and operational data by jurisdiction—revenue, profit, tax paid, tax accrued, stated capital, accumulated earnings, number of employees, and tangible assets. Compiling this data accurately and consistently requires robust systems and disciplined preparation.

The Nigerian Regulatory Framework

Income Tax (Country-by-Country Reporting) Regulations, 2018

Nigeria’s CbCR obligations are established under the Income Tax (Country-by-Country Reporting) Regulations, 2018 (the CbCR Regulations). The framework supports Nigeria’s commitment to BEPS Action 13 and was introduced following Nigeria’s signing of the Multilateral Competent Authority Agreement (MCAA) for automatic exchange of CbC reports in January 2016.

The CbCR Regulations have an effective date of 1 January 2018, meaning the first reporting fiscal year for Nigerian-headquartered groups began on or after that date.

Guidelines on the Appropriate Use of CbC Reports

The FIRS has issued Guidelines on the Appropriate Use of CbC Reports, which set out how the information may and may not be used. The NRS may use CbC Report information for high-level transfer pricing risk assessment, assessment of other BEPS-related risks, and economic and statistical analysis.

However, CbC Report information may not be used as a substitute for detailed transfer pricing analysis of individual transactions, as conclusive evidence that transfer prices are or are not appropriate, as a basis for proposing transfer pricing adjustments based on global formulary apportionment, or as a basis for adjustments to income based on an income allocation formula.

Who Must Comply?

Nigerian-Headquartered MNE Groups

A Nigerian-headquartered MNE group must file a CbC Report with the NRS if its consolidated group revenue in the preceding accounting year is ₦160 billion or more.

Nigerian Entities of Foreign MNE Groups

A Nigerian entity that is part of an MNE group headquartered outside Nigeria must notify the NRS of the identity and tax residence of the entity responsible for filing the CbC Report. The threshold in this case is based on the parent jurisdiction’s rules—typically the OECD threshold of €750 million.

Groups Operating Only in Nigeria

Groups that operate solely within Nigeria are not affected by the CbCR Regulations.

Two Distinct Compliance Obligations

The CbCR Regulations impose two separate obligations: the CbC Notification and the CbC Report.

CbC Notification

Every Nigerian Constituent Entity of a qualifying MNE group must file a notification with the NRS. The notification must disclose:

Details of the company making the notification
Whether the entity is the Ultimate Parent Entity (UPE) or Surrogate Parent Entity (SPE) of the group
The MNE group’s name
All Nigerian Constituent Entities and their Tax Identification Numbers (TINs)
The identity and tax residence of the Reporting Entity (the entity that will file the CbC Report)

Deadline: The notification is due no later than the last day of the Reporting Accounting Year of the MNE group.

CbC Report

The CbC Report is the substantive disclosure. It must contain, for each jurisdiction where the group operates:

Revenue – unrelated party and related party revenue
Profit or loss before income tax
Income tax paid – on a cash basis
Income tax accrued – on a current year basis
Stated capital
Accumulated earnings
Number of employees
Tangible assets other than cash and cash equivalents

The CbC Report must also list each Constituent Entity and its tax jurisdiction.

Deadline: The CbC Report is due 12 months after the last day of the Reporting Accounting Year.

Secondary Filing Obligation

Where the UPE or SPE of an MNE group is not tax resident in Nigeria, and the CbCR has not been implemented in the jurisdiction where the UPE or SPE is resident—or where that jurisdiction has no relevant exchange of information agreement with Nigeria—the Nigerian constituent entity is required to carry out a secondary filing. This means submitting a copy of the CbC Report to the NRS in Nigeria.

The Filing Process: Migration to the AEOI Portal

Nigeria’s CbCR filing process has undergone significant changes. The Federal Inland Revenue Service (FIRS) initially migrated CbCR notifications to TaxPro-Max in February 2024. However, TaxPro-Max could not accept CbC Reports, so reports were submitted via email.

The FIRS has now migrated CbCR filings to the Automatic Exchange of Information (AEOI) CbCR Portal, previously used for Common Reporting Standard (CRS) filings. The enhanced portal—FIRS/AEOI-CbCR Portal—allows MNEs to submit CbC Reports electronically.

Dual-Platform Compliance

As at the 2024 reporting year, MNEs are required to:

Submit the CbC Notification on TaxPro-Max
Enrol on the AEOI-CbCR Portal to submit the CbCR Notification and Report

The FIRS has indicated plans to integrate both platforms and eliminate dual filing, but that integration has not yet been completed.

Filing Format

CbC Reports must be uploaded in XML format, using the schema template available on the FIRS or OECD website.

Portal Access

The FIRS/AEOI-CbCR Portal is accessible at https://portal.aeoi.firs.gov.ng/.

Penalties for Non-Compliance

The CbCR Regulations prescribe significant penalties:

Default	Penalty
Late filing of CbC Report	₦10 million in the first instance, plus ₦1 million for each month the default continues
Failure to file CbC Notification	₦5 million in the first instance, plus ₦10,000 for each day of default
False declaration or incorrect information	₦10 million

Key Considerations for Compliance

Confirm Your Threshold Position. Determine whether your group meets the ₦160 billion consolidated revenue threshold. If headquartered abroad, confirm the parent jurisdiction’s threshold and whether an effective exchange of information arrangement exists with Nigeria.

Identify Your Reporting Entity. Determine whether your Nigerian entity is the UPE, SPE, or a Constituent Entity of a foreign-headed group. This determines your notification obligations.

Enrol on the AEOI Portal Early. Registration and testing should be completed well before the filing deadline. Portal access can take time to activate.

Prepare the XML Schema. CbC Reports must be filed in XML format. Ensure your systems can generate the required schema before the deadline.

Maintain Contemporaneous TP Documentation. The CbC Report is not a substitute for Master File and Local File documentation. Nigeria requires both, and the CbC Report is a separate compliance layer.

How Qeeva Advisory Helps with CbCR Compliance

Our Core Services

Transfer Pricing Advisory – We help you prepare CbC Reports, CbCR Notifications, and related transfer pricing documentation, including Master File and Local File.

Transfer Pricing Documentation Burndown – We help you close documentation gaps and maintain audit-ready TP files.

Tax Advisory Services – We help you navigate Nigeria’s tax system, including CbCR and transfer pricing compliance.

Tax Audit Defense Service – We provide comprehensive support for businesses facing transfer pricing and CbCR-related audits.

Tax Risk & Governance Advisory – We help you build tax control frameworks that integrate with CbCR compliance.

Advisory Services Nigeria – Our advisory professionals provide strategic guidance on CbCR compliance, regulatory engagement, and dispute resolution.

Our CbCR Compliance Methodology

Phase 1: Threshold and Scope Assessment – We determine your group’s CbCR obligations based on consolidated revenue, entity roles, and jurisdiction of the UPE.

Phase 2: Data Collection and Validation – We help compile the financial and operational data required for the CbC Report, ensuring consistency with financial statements and TP documentation.

Phase 3: Notification and Report Preparation – We prepare the CbC Notification and CbC Report in the required XML format.

Phase 4: Portal Registration and Filing – We support enrolment on the AEOI-CbCR Portal and submission on both required platforms.

Phase 5: Ongoing Monitoring – We track regulatory developments and filing deadlines to ensure sustained compliance.

Frequently Asked Questions

Q: What is the CbCR threshold for Nigerian-headquartered groups?

A: ₦160 billion in consolidated group revenue in the preceding accounting year.

Q: When is the CbC Report due?

A: 12 months after the last day of the Reporting Accounting Year.

Q: When is the CbC Notification due?

A: By the last day of the Reporting Accounting Year.

Q: Where do I file the CbC Report?

A: On the FIRS/AEOI-CbCR Portal at https://portal.aeoi.firs.gov.ng/.

Q: Do I still need to file on TaxPro-Max?

A: Yes, as at the 2024 reporting year, the CbC Notification must also be submitted on TaxPro-Max. The FIRS plans to integrate the platforms.

Q: What is the penalty for late filing?

A: ₦10 million in the first instance, plus ₦1 million for each month of default.

Q: What format must the CbC Report be in?

A: XML format, using the schema template from the FIRS or OECD website.

Q: How can Qeeva Advisory help with CbCR compliance?

A: We provide threshold and scope assessment, data collection and validation, notification and report preparation, portal registration and filing support, and ongoing monitoring.

The Bottom Line

Country-by-Country Reporting is not a voluntary disclosure—it is a mandatory annual obligation for large MNE groups operating in Nigeria. With the migration to the AEOI-CbCR Portal and dual-platform filing requirements, compliance requires technical expertise, accurate data, and disciplined filing.

Key Takeaways:

Confirm Your Threshold – Nigerian-headquartered groups: ₦160 billion. Foreign-headed groups: parent jurisdiction threshold (typically €750 million).

File Both Notification and Report – The CbC Notification is due by the last day of the Reporting Accounting Year. The CbC Report is due 12 months after.

Use the AEOI-CbCR Portal – The FIRS has migrated CbC Report filing to https://portal.aeoi.firs.gov.ng/.

Meet the XML Format Requirement – CbC Reports must be filed in XML format.

Avoid the Penalties – Late filing: ₦10 million plus ₦1 million monthly. Notification failure: ₦5 million plus ₦10,000 daily.

Your job is to be prepared. Confirm your threshold. Identify your reporting entity. Enrol on the portal. Prepare your data. File on time. Seek professional guidance.

With the right approach and the right partner, you can turn CbCR compliance from a regulatory burden into a demonstration of disciplined tax governance.

Reference Links / Sources

Qeeva Advisory – Transfer Pricing Advisory – Master File, Local File, CbCR, and comparability analysis.

Qeeva Advisory – Transfer Pricing Documentation Burndown – TP documentation gap remediation.

Qeeva Advisory – Master File vs. Local File – Two-tier documentation structure.

Qeeva Advisory – Understanding Related-Party Transactions – Controlled transaction identification and management.

Qeeva Advisory – Tax Advisory Services – Tax compliance and planning.

Qeeva Advisory – Tax Audit Defense Service – Pre-audit preparation and documentation compilation.

Qeeva Advisory – Tax Risk & Governance Advisory – Tax control frameworks and governance.

Qeeva Advisory – Advisory Services Nigeria – CbCR compliance and regulatory engagement.

Let’s Talk About Your CbCR Compliance Needs

CbCR compliance requires accurate data, disciplined filing, and awareness of changing portal requirements. At Qeeva Advisory, we understand the CbCR challenges faced by Nigerian MNEs and constituent entities.

Whether you need help with threshold assessment, data collection, notification preparation, or portal filing, we are here to support you.

📞 Call us: (+234) 802 320 0801, (+234) 807 576 5799

📧 Email: info@qeeva.com

📍 Visit us: 5, Ishola Bello Close, Off Iyalla Street, Alausa, Ikeja, Lagos, Nigeria

Contact us today to schedule a CbCR consultation. Let us help you meet your CbCR obligations with confidence.

Your journey to CbCR compliance starts with a conversation. Let’s talk.

Country-by-Country Reporting Explained: A Complete Guide

COUNTRY-BY-COUNTRY REPORTING EXPLAINED

Introduction