Transfer Pricing Advisory Service
Comply with Confidence. Defend Your Position. Manage Risk.
Transfer pricing has become one of the most significant tax issues for multinational enterprises and large Nigerian companies. The Federal Inland Revenue Service (FIRS) has intensified enforcement, deploying real-time data, e-invoicing information, cross-border reporting frameworks, and risk-based audit tools . Nigeria loses an estimated US$15-20 billion annually, mostly from the oil and gas sector, due to tax evasion and avoidance . The Nigeria Tax Administration Act (NTAA) 2025 has extended the statute of limitations for tax reviews, meaning older transactions remain open to scrutiny for longer, and new penalty provisions could materially increase financial exposure for companies under audit . At Qeeva Advisory, we provide transfer pricing advisory services that help you comply with confidence, defend your position, and manage risk.
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Why Nigerian Businesses Need Transfer Pricing Advisory
Nigeria’s transfer pricing regime has evolved significantly, and enforcement is intensifying. Here are the most critical gaps we help you address.
Increased FIRS Enforcement – The FIRS has ramped up transfer pricing audits, relying more on real-time data, e-invoicing information, cross-border reporting frameworks, and risk-based audit tools . The authority has increased its team size and expects increased intensity on audit .
Expanded Statute of Limitations – The NTAA 2025 extended the statute of limitations for certain tax reviews, allowing older transactions to remain open to scrutiny for longer . This increases the risk that historical transfer pricing positions may be challenged.
Substantial Penalties for Non-Compliance – Failure to submit TP documentation within 21 days of a FIRS request attracts a penalty of ₦10 million or 1% of the total value of all controlled transactions, whichever is higher, plus ₦10,000 for every day in which the failure continues . Failure to make disclosures of controlled transactions attracts a penalty of ₦10 million or 1% of the value of controlled transactions not disclosed, whichever is higher, and ₦10,000 for every day in which the failure continues .
Complex Documentation Requirements – Nigeria requires the three-tier documentation approach recommended by the OECD: Master File, Local File, and Country-by-Country (CbC) Report . Taxpayers must prepare contemporaneous documentation substantiating the arm’s length nature of transactions .
Arm’s Length Principle Complexity – The arm’s length principle mandates that all transactions between related companies must be priced as though the parties were independent entities negotiating on open market terms . Determining the most appropriate transfer pricing method requires analysis of functions performed, assets employed, and risks assumed .
Intra-Group Services and Management Fees – Management fees and intra-group service charges are likely to remain key pressure points in future audits . Service charges must be for services actually rendered and provide economic or commercial value to the recipient .
Financing Transactions – Related-party loans require evidence of arm’s-length interest rates, appropriate debt-to-equity ratios, and commercial rationale. Nigeria’s 3:1 thin-capitalization rule heightens compliance requirements .
Intangible Property Challenges – IP transactions face scrutiny around the valuation of licenses/transfers, allocation of intangible-related returns, DEMPE documentation, and justification of royalty or profit allocation arrangements .
Commodity Transactions – For exports, if the related-party price is lower than the quoted price, the quoted price shall be the sale price for tax purposes unless adjustments are justified. For imports, if the related-party price is higher than the quoted price, the quoted price shall be the sale price .
Royalty Deduction Limitations – Regulation 7(5) of the TP Regulations restricts royalty deductions to 5% of EBITDAC derived from the commercial activity in which the rights transferred are exploited .
Global Minimum Tax and BEPS – The NTA 2025 introduces provisions for a global minimum corporate tax rate and expands Significant Economic Presence (SEP) thresholds, aligning Nigeria more closely with global tax transparency standards .
The Solution: Strategic Transfer Pricing Advisory
We provide transfer pricing advisory services that help you comply with confidence, defend your position, and manage risk. Our approach combines deep technical expertise in Nigerian TP regulations, practical documentation support, and audit defence capability.
At Qeeva Advisory, we understand that transfer pricing is not just a compliance exercise—it is a strategic issue that affects where profits are taxed and how much tax your business pays. Our team brings deep expertise in Nigerian transfer pricing regulations, OECD guidelines, and FIRS audit practices.
We help you design TP policies, prepare documentation, file returns, and defend your position during audits. We help you manage the risks and seize the opportunities presented by Nigeria’s evolving TP landscape.
Whether you need TP policy design, documentation preparation, audit defence, or Advance Pricing Agreement support, we provide the expertise and commitment to help you succeed.
Our Comprehensive Transfer Pricing Advisory Services
We offer end-to-end transfer pricing advisory services tailored to the Nigerian tax environment.
Transfer Pricing Policy Design
We help you design TP policies that align with your business model and comply with Nigerian regulations.
Functional Analysis – We conduct functional analysis that identifies the functions performed, assets employed, and risks assumed by each party to controlled transactions. This analysis forms the foundation for method selection and benchmarking .
Transfer Pricing Method Selection – We select the most appropriate transfer pricing method from the five prescribed methods: Comparable Uncontrolled Price (CUP), Resale Price, Cost Plus, Transactional Net Margin (TNMM), and Transactional Profit Split .
Arm’s Length Analysis – We conduct arm’s length analyses that determine whether controlled transactions are priced consistently with the arm’s length principle.
Intra-Group Service Policies – We design policies for intra-group services, ensuring service charges are for services actually rendered and provide economic or commercial value .
Financing Policies – We design policies for related-party loans and financing, ensuring arm’s-length interest rates and appropriate debt-to-equity ratios .
Intangible Property Policies – We design policies for IP transactions, including licenses, transfers, and royalty arrangements .
Commodity Transaction Policies – We design policies for commodity transactions, ensuring compliance with the quoted price rules .
Transfer Pricing Documentation
We prepare comprehensive documentation that meets Nigerian requirements and OECD standards.
Master File Preparation – We prepare the Master File, which provides an overview of the global business operations of the MNE Group, including its structure, business model, and transfer pricing policies .
Local File Preparation – We prepare the Local File, which provides detailed information on the Nigerian entity’s related-party transactions, including functional analysis, comparability analysis, and economic support for the pricing applied .
Country-by-Country (CbC) Report – We prepare the CbC Report for Nigeria-headquartered MNE Groups with consolidated revenue of ₦160 billion or above .
CbC Notification – We prepare CbC notifications for Nigeria-resident members of MNE Groups headquartered outside Nigeria .
Benchmarking Studies – We conduct benchmarking studies that use appropriate comparables to support your transfer pricing positions .
Contemporaneous Documentation – We prepare contemporaneous documentation that substantiates the arm’s length nature of your controlled transactions .
Transfer Pricing Returns and Filings
We prepare and file TP returns and disclosures.
TP Declaration Form – We prepare the TP Declaration form, which contains general information about the company, including shareholding structure and details of connected parties .
TP Disclosure Form – We prepare the TP Disclosure form, which contains information on the nature and value of controlled transactions, the method used, and the tax jurisdictions of connected parties .
Annual TP Returns – We file annual TP returns alongside the corporate tax returns .
Filing Deadline Compliance – We ensure TP returns are filed within the required timeframe—not later than 18 months after incorporation or within 6 months after the end of the accounting year, whichever is earlier .
Extension Applications – We prepare applications for extension of time to file returns where required .
Transfer Pricing Audit Defence
We defend your transfer pricing position during FIRS audits.
Audit Preparation – We prepare you for transfer pricing audits, ensuring documentation is complete and defensible.
Audit Representation – We represent you during FIRS transfer pricing audits.
Documentation Submission – We manage the submission of TP documentation within 21 days of a FIRS request .
Technical Defence – We provide technical defence on method selection, comparability analysis, and arm’s length pricing.
Position Papers – We prepare position papers that explain and support your transfer pricing position.
Negotiation – We negotiate with FIRS to resolve transfer pricing disputes.
Penalty Mitigation – We support penalty mitigation where non-compliance has occurred.
Transfer Pricing Risk Assessment
We help you identify and manage transfer pricing risks.
TP Health Check – We conduct TP health checks that identify risks and improvement opportunities.
Risk Assessment – We assess your exposure to transfer pricing adjustments, penalties, and interest.
Gap Analysis – We identify gaps in your TP documentation, policies, and compliance.
Benchmarking Review – We review your benchmarking studies for appropriateness and reliability.
Related-Party Transaction Review – We review your related-party transactions, identifying high-risk areas.
Intercompany Agreement Review – We review intercompany agreements for consistency with your TP policies.
Advance Pricing Agreements (APAs)
We help you obtain advance pricing agreements for certainty.
APA Eligibility Assessment – We assess whether you meet the eligibility criteria for an APA, including the minimum threshold of USD 10 million per annum for each covered controlled transaction or USD 50 million per annum for a group of transactions .
APA Application Preparation – We prepare the APA application, including detailed information on business activities, intercompany dealings, functional and risk analysis, and proposed methodology .
APA Negotiation – We support negotiation with FIRS throughout the APA process .
APA Compliance and Monitoring – We support ongoing compliance with APA terms, including annual reporting and documentation retention .
Bilateral and Multilateral APAs – We support bilateral and multilateral APAs involving foreign tax authorities .
Transfer Pricing for Specific Transactions
We provide specialised advisory for specific transaction types.
Intra-Group Services – We advise on management fees, technical services, and shared service arrangements .
Financing Transactions – We advise on related-party loans, guarantees, and cash pooling arrangements .
Intangible Property – We advise on IP licenses, transfers, and royalty arrangements .
Commodity Transactions – We advise on commodity exports and imports, ensuring compliance with quoted price rules .
Business Restructuring – We advise on transfer pricing implications of business restructurings.
Supply Chain Planning – We advise on supply chain structures that align with transfer pricing requirements.
Transfer Pricing Training and Capacity Building
We help you build internal transfer pricing capability.
TP Awareness Training – We deliver training on Nigerian transfer pricing regulations and compliance requirements.
Finance Team Training – We train finance teams on TP documentation, returns, and audit defence.
Transfer Pricing Workshops – We facilitate workshops that build practical TP skills.
Best Practice Benchmarking – We benchmark your TP practices against leading practices.
Key Transfer Pricing Requirements in Nigeria
We help you meet all key requirements.
| Requirement | Details |
|---|---|
| Documentation Threshold | Total value of controlled transactions exceeding ₦300 million |
| Master File | Provides overview of global business operations and TP policies |
| Local File | Detailed information on Nigerian entity’s related-party transactions |
| CbC Report | Required for MNE Groups with consolidated revenue of ₦160 billion or above |
| CbC Notification | Required for Nigeria-resident members of foreign-headquartered MNE Groups |
| TP Declaration | General information about the company and connected parties |
| TP Disclosure | Information on nature, value, and method of controlled transactions |
| Filing Deadline | Within 18 months of incorporation or 6 months after year-end, whichever is earlier |
| Documentation Submission | Within 21 days of FIRS request |
| Documentation Retention | Six years (or longer where fraud, negligence, or willful default) |
| Arm’s Length Principle | All related-party transactions must be at arm’s length |
| Thin Capitalization | 3:1 debt-to-equity ratio |
| Royalty Deduction Limit | 5% of EBITDAC for related-party royalties |
| Commodity Transactions | Quoted price rules apply for exports and imports |
Penalties for Non-Compliance
We help you avoid substantial penalties.
| Non-Compliance | Penalty |
|---|---|
| Failure to Submit TP Declaration | ₦25,000 for each day the failure continues |
| Failure to Submit TP Disclosure | ₦10 million or 1% of value of controlled transaction not disclosed, whichever is higher, plus ₦10,000 per day |
| Failure to Submit TP Documentation | ₦10 million or 1% of total value of controlled transactions, whichever is higher, plus ₦10,000 per day |
| Failure to File CbC Report | ₦10 million in first instance, plus ₦1 million for every month of default |
| Filing Incorrect or False CbC Report | ₦10 million |
| Transfer Pricing Adjustment | Additional corporate income tax at 30% |
| Understatement Penalty | 10% of underpaid tax plus interest |
Industries We Serve
We provide transfer pricing advisory services across multiple sectors in Nigeria.
Oil and Gas – We advise on transfer pricing for oil and gas companies, including commodity transactions, intra-group services, and financing. The sector contributes about 65% of government revenue and is a key focus for FIRS enforcement .
Banking and Financial Services – We advise banks, insurance companies, and financial institutions on transfer pricing for financing transactions and intra-group services.
Manufacturing – We advise manufacturers on transfer pricing for raw materials, finished goods, and management fees.
Technology and Digital – We advise tech companies on transfer pricing for digital services, IP transactions, and SEP rules .
Retail and Consumer Goods – We advise retailers and FMCG companies on transfer pricing for goods, services, and intangibles.
Pharmaceuticals and Healthcare – We advise pharmaceutical companies on transfer pricing for IP, licensing, and intra-group services.
Telecommunications – We advise telecom companies on transfer pricing for network services, IP, and management fees.
Professional Services – We advise professional service firms on transfer pricing for intra-group services.
Conglomerates – We advise diversified groups with multiple entities on transfer pricing across business lines.
Multinational Enterprises – We advise MNEs operating in Nigeria on transfer pricing compliance, documentation, and audit defence .
SMEs – We provide accessible transfer pricing advisory for SMEs with related-party transactions.
Private Equity and Venture Capital – We advise funds and portfolio companies on transfer pricing for management fees and intra-group services.
Our Engagement Process
We follow a structured, collaborative process to deliver high-impact transfer pricing advisory.
Phase 1: Discovery and Assessment – We understand your business, related-party transactions, and transfer pricing position. We conduct TP health checks and risk assessments.
Phase 2: Strategy and Design – We design TP policies, select methods, and develop documentation strategies.
Phase 3: Documentation and Filing – We prepare Master File, Local File, CbC Report, TP Declaration, and TP Disclosure. We file returns on time.
Phase 4: Audit Defence – We prepare for and defend transfer pricing audits. We represent you before FIRS.
Phase 5: Monitoring and Continuous Improvement – We monitor regulatory changes, update documentation, and refine TP policies as your business evolves.
Why Choose Qeeva Advisory for Transfer Pricing Advisory
Deep TP Expertise – We have deep expertise in Nigerian transfer pricing regulations, OECD guidelines, and FIRS audit practices. We understand the complexities of the arm’s length principle and method selection.
Nigerian Market Knowledge – We understand the Nigerian TP landscape, including the NTA 2025 changes, SEP rules, and FIRS enforcement priorities.
Practical and Actionable – We provide practical solutions tailored to your business size, industry, and specific challenges.
Documentation Excellence – We prepare documentation that meets Nigerian requirements and OECD standards, and withstands audit scrutiny.
Audit Defence Capability – We have experience defending transfer pricing positions during FIRS audits, including technical defence and negotiation.
APA Support – We support Advance Pricing Agreement applications for taxpayers seeking certainty .
End-to-End Support – We provide comprehensive services from policy design to documentation to audit defence.
Training and Capability Building – We train your team and build internal TP capability.
Long-Term Partnership – We build lasting relationships, providing ongoing support as your business evolves and regulations change.
Confidentiality and Integrity – We treat your business and tax information with the highest level of confidentiality.
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Suggested Reading
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Common Accounting Errors That Affect Profitability in Nigeria – Accounting errors quietly drain profits, attract penalties, and limit growth.
Preparing a Business for External Audits in Nigeria – External audits can be daunting, but with the right preparation, they become an opportunity to demonstrate your business’s financial integrity.
Deferred Tax Asset Validation Burndown: Complete Guide for Nigerian Businesses – Deferred tax asset validation is a critical financial reporting discipline.
Anti-Money Laundering Compliance for Non-Financial Firms in Nigeria – Money laundering represents one of the most significant threats to global financial integrity.
Frequently Asked Questions (FAQ)
1. What is transfer pricing?
Transfer pricing refers to the pricing of transactions between related companies within a multinational group. It governs how related companies price cross-border transactions such as management fees, royalties, intra-group services, and goods supplied between subsidiaries .
2. Why is transfer pricing important in Nigeria?
Transfer pricing is important because it determines how multinational groups allocate income, costs, and profits across borders, and ultimately where tax is paid . The FIRS has intensified enforcement, and non-compliance attracts substantial penalties.
3. What is the arm’s length principle?
The arm’s length principle mandates that all transactions between related companies must be priced as though the parties were independent entities negotiating on open market terms .
4. What documentation is required?
Nigeria requires the three-tier documentation approach: Master File, Local File, and Country-by-Country (CbC) Report . Taxpayers must also file TP Declaration and TP Disclosure forms.
5. Who needs to prepare transfer pricing documentation?
Taxpayers with related-party transactions exceeding ₦300 million in total value must maintain contemporaneous documentation .
6. When is the filing deadline?
TP returns must be filed not later than 18 months after incorporation or within 6 months after the end of the accounting year, whichever is earlier .
7. How long do I have to submit documentation if FIRS requests it?
Documentation must be submitted within 21 days of receiving a FIRS request .
8. What are the penalties for non-compliance?
Penalties include ₦10 million or 1% of controlled transaction value for failure to disclose, ₦10 million for failure to submit documentation, and ₦25,000 per day for failure to submit TP declaration .
9. What is the thin capitalization rule?
Nigeria’s 3:1 thin-capitalization rule limits interest deductions on related-party debt to a 3:1 debt-to-equity ratio .
10. What is the royalty deduction limit?
Regulation 7(5) restricts royalty deductions to 5% of EBITDAC derived from the commercial activity in which the rights transferred are exploited .
11. What is an Advance Pricing Agreement (APA)?
An APA is an agreement between a taxpayer and FIRS that predetermines transfer pricing methodology, comparables, and critical assumptions for related-party transactions over a fixed period .
12. What are the APA eligibility thresholds?
The minimum threshold is USD 10 million per annum for each covered controlled transaction or USD 50 million per annum for a group of transactions .
13. What is the statute of limitations for transfer pricing assessments?
The statute of limitation is six years, meaning all supporting documentation must be retained for six years. In cases of fraud, negligence, or willful default, there is no statute of limitations .
14. Do you serve businesses outside Lagos?
Yes. While our head office is in Ikeja, Lagos, we serve businesses across Nigeria. Our transfer pricing advisory services are available to clients regardless of location.
15. How do I get started?
Contact us to schedule your free consultation. We’ll discuss your transfer pricing needs, assess your situation, and provide recommendations for how we can help.
Contact Us
Comply with confidence, defend your position, and manage risk. Let us build a partnership that strengthens your transfer pricing position.
Schedule Your Free Consultation to discuss your transfer pricing advisory needs and explore how we can help.
Phone: +234 802 320 0801, +234 807 576 5799
Email: info@qeeva.com
Address: 5, Ishola Bello Close, Off Iyalla Street, Alausa, Ikeja, Lagos, Nigeria
Business Hours: Monday to Friday, 8:00 AM – 6:00 PM WAT
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