Nigeria’s Federal Inland Revenue Service (FIRS) has released detailed guidelines on Advance Pricing Agreements (APAs), providing a framework for companies to establish transfer pricing agreements with tax authorities in advance.
Businesses meeting the eligibility criteria can opt for unilateral, bilateral, or multilateral Advance Pricing Agreements (APAs), subject to specific financial thresholds.
The guidance outlines the procedures for managing executed APAs as well as key operational procedures and compliance obligations.
Companies with a taxable presence in Nigeria can apply for an APA if their intercompany transactions meet annual thresholds of USD 10 million for a single transaction or USD 50 million for a group of intercompany transactions.
To apply for an APA, taxpayers must pay a nonrefundable USD 20,000 deposit to the FIRS and a deposit of USD 5,000 for renewals.
The guidance will be effective starting 1 January 2025.
