The Federal Inland Revenue Service (FIRS) has previously released the Income Tax (Transfer Pricing) Regulations, 2018, which replaced the Income Tax (Transfer Pricing) Regulations, 2012. The 2018 TP Regulations, which introduced supplementary compliance obligations for taxpayers and enhanced administrative penalties for any non-compliance with the obligations and applies to financial years beginning after 12 March 2018. Again, on October 3, 2018, the FIRS issued a public notice for notifying taxpayers about the deadline for satisfying transfer pricing requirements. FIRS has approved the deadline up to December 31, 2018 to ensure their full compliance with all incomplete transfer pricing (TP) obligations; such as submission of TP declarations, disclosures and submission of TP documentation, etc. Under FIRS, increased administrative penalties will be imposed in case of any non-compliance with the obligations. This notice helps to clear some of the uncertainties taxpayers have on the administrative procedures for implementation of the 2018 TP Regulations.
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