On 23 May 2023, the Federal Inland Revenue Service (FIRS) of Nigeria has released Information Circular No. 2023/04 which includes new Guidelines on Mutual Agreement Procedure (MAP).
The purpose of the guidelines is to provide guidance on how to obtain assistance from the Nigerian Competent Authority (CA) by a taxpayer whose tax case falls within the scope of a tax treaty between Nigeria and another contracting state. This assistance is provided to taxpayers to enable resolution of tax disputes bordering on double taxation and inconsistencies in the interpretation or application of the provisions of a Tax Treaty. The guidelines also provide additional guidance on the application for corresponding adjustments that may be required due to the application of the Article on associated enterprises in a tax treaty.
