In September 2013, the Organization for Economic Co-operation and Development (OECD) and G20 countries, working together on an equal footing, adopted an ambitious and comprehensive 15-point Action Plan to address BEPS. The Action Plan aims to ensure that profits are taxed where economic activities generating the profits are performed and where value is created. In response to this requirement, jurisdictions participating in the BEPS Project agreed on revised standards for transfer pricing documentation and a template for country-by-country reporting of income, taxes paid and certain measures of economic activity. On 16 September 2014, the OECD published the “Guidance on Transfer Pricing Documentation and Country-by-Country Reporting” that provided template for country-by-country reporting.
Recently, the Federal Inland Revenue Service (FIRS) has updated its CbC reporting guidance page through a public notice on the suspension of local filing requirement for non-parent constituent entities until further notice. Other requirements such as the filing of CbC notifications continue to apply. Nigeria is a member of the Inclusive Framework, a group of jurisdictions, committed to the implementation of the minimum standards of the BEPS related measures. Nigeria signed the Multilateral Competent Authority Agreement on Country-by-Country Reporting (CbC MCAA) in January 2016 and has produced the Income Tax (CbC reporting) Regulations 2018 (“CbC Regulations”) for the implementation of the Country-by-Country Reporting in Nigeria.
