The Federal Inland Revenue service (FIRS) issued a public notice to suspend Regulation 4 of the “Income Tax (CbC Regulations) Regulations, 2018”. This public notice notifies branches and subsidiaries of Multinational Enterprises (MNEs) operating in Nigeria that the implementation of local filing requirements i.e. by filing CbC reports to the Federal Inland Revenue Service is suspended until further notice.
Regulation 4 of the “Income Tax (Country-by-Country (CbC) Reporting) Regulations, 2018” requires branches and subsidiaries of MNEs operating in Nigeria to submit their CbC reports to the FIRS when there is no automatic exchange of information mechanism existing between Nigeria and the country of residence of the “ultimate parent entity“ (UPE).