Transfer Pricing Rules: What Nigerian Multinationals Must Know

The Hidden Tax Risk Your Multinational Business Is Facing Right Now

In 2024, the Federal Inland Revenue Service (FIRS) initiated transfer pricing audits against 47 multinational enterprises operating in Nigeria, resulting in combined tax adjustments exceeding ₦8.2 billion. Most of these companies operated under the mistaken belief that their internal pricing arrangements between subsidiaries, parent companies, and related entities were simply "business decisions" beyond the scrutiny of tax authorities. They were wrong.

Transfer pricing isn't a obscure tax concept relegated to Fortune 500 companies with dedicated tax departments. If your organization has any commercial arrangement with a related party—whether that's a sister company in Ghana, a parent entity in the United States, a manufacturing affiliate in Singapore, or even a partnership with a family-controlled business—you are subject to Nigeria's transfer pricing regulations. And the stakes are extraordinarily high.

Non-compliance doesn't just result in additional tax assessments. According to Section 192 of the Nigeria Tax Act 2025, the FIRS has explicit authority to make adjustments to any transaction between related parties that it deems not to be at arm's length. These adjustments can trigger penalties, interest charges, and reputational damage that extends far beyond the tax bill itself. For multinational enterprises already operating with thin profit margins in Nigeria's competitive market, a poorly managed transfer pricing position can be the difference between profitability and loss.

This comprehensive guide walks you through everything you need to know about Nigeria's transfer pricing framework, how to ensure compliance, and—critically—how to structure your related party arrangements to withstand FIRS scrutiny. We've analyzed the specific language in Section 192 of the Nigeria Tax Act 2025, reviewed the transfer pricing regulations framework, and compiled practical strategies used by Nigeria's leading multinational enterprises to maintain compliance while optimizing their tax positions.

Understanding Transfer Pricing: The Core Principle That Governs All Related Party Transactions

Transfer pricing refers to the price at which one related party charges another for goods, services, tangible assets, intangible assets, loans, leases, financing arrangements, and any other commercial transactions. The fundamental principle governing all transfer pricing in Nigeria is the "arm's length principle," which is enshrined in Section 192(4)(b) of the Nigeria Tax Act 2025.

The arm's length principle states that transactions between related parties must be priced as if those parties were independent entities dealing at arm's length in comparable circumstances. In practical terms, this means: if your Nigerian subsidiary purchases raw materials from your parent company in the United Kingdom, the price paid must reflect what an independent buyer in Nigeria would pay for those same materials from an independent seller under comparable market conditions.

Why does this matter? Without the arm's length principle, multinational enterprises could artificially manipulate profits. A parent company could charge its Nigerian subsidiary inflated prices for goods or services, thereby shifting profits from Nigeria (a high-tax jurisdiction) to a lower-tax country. Conversely, a parent company could pay below-market prices for goods manufactured by its Nigerian subsidiary, again shifting profits away from Nigeria. Both scenarios result in tax evasion and deprive Nigeria's government of legitimate tax revenue.

The FIRS recognizes this risk explicitly. According to the official Tax Manual guidance on transfer pricing regulations, the objectives of Nigeria's transfer pricing framework include ensuring that "tax is assessed on the appropriate taxable basis corresponding to the economic activities deployed by taxable persons in Nigeria, including transactions and dealings by related persons" and to "provide the legal tools to fight tax evasion that may arise through over- or underpricing of transactions between related persons."

What makes Nigeria's transfer pricing framework particularly stringent is that compliance is not optional. Section 192(1) of the Nigeria Tax Act 2025 explicitly states: "A company involved in an arrangement with a related party shall (a) ensure that the terms and conditions for which the arrangement is carried out is at arm's length; and (b) report the arrangement in the form and manner prescribed by the relevant tax authority."

This creates a two-fold obligation: first, you must actually structure your transactions at arm's length; second, you must document and report these transactions to the FIRS. Failure on either front exposes you to adjustment and penalties.

The Legal Framework: Section 192 of the Nigeria Tax Act 2025 and What It Means for Your Business

Connected Persons: Who is Covered by Transfer Pricing Rules?

The first question every multinational must answer is: "Are we connected persons under Nigerian tax law?" Section 192 applies to any "arrangement with a related party," and the Tax Manual provides a comprehensive definition of connected persons.

According to the official guidance, persons are deemed connected where one person has the ability to control or influence the other person in making financial, commercial, or operational decisions, or where a third person has the ability to control or influence both persons. The definition is intentionally broad and covers:

• Parent company and subsidiaries
• Sister companies under common ownership
• Associates and joint ventures
• Partnerships where one partner has control or influence over another
• Permanent establishments and their head offices
• Dependent agents
• Individuals with common control over multiple entities

Importantly, the connection doesn't require majority ownership. Even if your company owns only 30% of another entity, if that ownership translates into the ability to influence financial or operational decisions, the transfer pricing rules apply. This is why many Nigerian companies discover, during FIRS audits, that transactions they believed were at arm's length were actually subject to transfer pricing documentation requirements.

The Scope of Controlled Transactions Subject to Transfer Pricing Rules

Transfer pricing regulations apply to a remarkably broad range of transactions. According to the Tax Manual, the scope includes:

Tangible Asset Transactions: Sale, purchase, lease, or licensing of physical property including machinery, equipment, inventory, real estate, and vehicles. When your Lagos manufacturing subsidiary sells finished goods to your Port Harcourt affiliate, transfer pricing rules apply.

Intangible Asset Transactions: Transfer, purchase, license, or use of intellectual property including patents, trademarks, copyrights, software, brand names, know-how, and customer relationships. This is particularly important for tech multinationals and consumer brands. When your Nigerian subsidiary licenses your parent company's proprietary software, the royalty rate must be at arm's length.

Service Provision: Any provision of services between related parties, including management services, technical assistance, administrative support, marketing services, and research and development. Many multinational enterprises charge their Nigerian subsidiaries annual management fees—these fees must reflect the fair market value of services provided.

Financing Arrangements: Lending or borrowing money between related parties. The interest rate charged on inter-company loans must reflect market rates for comparable loans. This is where many Nigerian companies face FIRS challenges. A parent company cannot loan funds to its Nigerian subsidiary at 0.5% interest when comparable third-party loans would carry 12% interest.

Manufacturing and Risk-Sharing Arrangements: Manufacturing arrangements where one related party manufactures goods on behalf of another, as well as any arrangement where risks and returns are shared among related parties.

Other Profit-Affecting Transactions: Essentially any transaction or arrangement that may affect profit and loss or any matter incidental to the foregoing.

The FIRS's Adjustment Powers Under Section 192(2)

Section 192(2) grants the FIRS explicit authority to make adjustments to related party transactions. The provision states: "Where, in the opinion of a relevant tax authority, a company has entered into an arrangement with a related party which is not at arm's length, it may effect necessary adjustments to bring the arrangement in conformity to arm's length terms as provided under the Transfer Pricing Regulations."

The language "in the opinion of a relevant tax authority" is critical. The FIRS doesn't need to prove beyond doubt that your pricing was improper; it only needs to form an opinion that the arrangement was not at arm's length. This standard is relatively low, which is why documentation becomes so critical. Strong transfer pricing documentation can rebut the FIRS's opinion and protect your company from adjustment.

In-Depth Analysis: How Transfer Pricing Rules Actually Work in Practice

The Comparability Analysis: The Heart of Transfer Pricing Compliance

Demonstrating that your related party transaction is at arm's length requires what tax professionals call a "comparability analysis." This is fundamentally an economic exercise: you must identify comparable transactions between independent parties and prove that your related party transaction reflects similar pricing.

Consider a practical example. Suppose your Nigerian subsidiary manufactures automotive components and sells them to your parent company's subsidiary in South Africa. To determine if this transfer price is at arm's length, you must identify similar transactions in which independent manufacturers sell comparable components to independent buyers under comparable circumstances. You might research: What prices do independent manufacturers in Nigeria charge for similar components? What price does the South African subsidiary pay to independent suppliers? What are the manufacturing costs, profit margins, and commercial terms?

This comparability analysis is the evidentiary foundation for your transfer pricing position. The FIRS conducts its own comparable analysis to challenge your pricing. If your analysis is thorough and well-documented, you can defend your position. If it's absent or superficial, the FIRS will make an adjustment and levy penalties.

Functional Analysis: Understanding What Each Party Actually Does

A transfer pricing analysis requires a clear understanding of the functions performed, assets employed, and risks assumed by each party to the transaction. This is called a "functional analysis."

For example, if your parent company manufactures a product in Nigeria and sells it to a related party distributor in Ghana, the functional analysis must answer: What does the manufacturer actually do? Does it own the manufacturing facility? Does it bear inventory risk? Does it conduct quality control? What assets does it deploy? What risks does it assume if sales decline or product defects emerge?

Similarly, what does the distributor do? Does it conduct marketing? Does it hold inventory? Does it bear credit risk if customers don't pay? Does it handle customer service? The higher the functions performed, the higher the risk assumed, and the higher the profit margin justified.

The FIRS specifically looks at functional analysis in transfer pricing audits. During a 2023 FIRS audit of a multinational pharmaceutical company in Nigeria, auditors challenged the company's transfer price for products supplied by its parent company because the functional analysis failed to account for the parent's extensive product development, regulatory compliance, and quality assurance functions. The company's initial transfer pricing study had simply referenced average industry markups without analyzing the specific functions performed by each party.

Documentation Requirements: What You Must Prepare and Maintain

Section 192(1) requires companies to "report the arrangement in the form and manner prescribed by the relevant tax authority." This reporting obligation requires transfer pricing documentation. In Nigeria, companies typically need to prepare:

Master File Documentation: A comprehensive description of your multinational group, its organizational structure, governance, transfer pricing policies, intangible assets, and inter-company financing arrangements. The master file provides context for specific transfer pricing transactions.

Functional Transfer Pricing Study: A detailed analysis of each material related party transaction, including functional analysis, economic analysis, benchmarking analysis, and selection of the appropriate transfer pricing method. This must be prepared before you file your tax return.

Country-by-Country Reporting (CbCR): If your multinational group has revenue exceeding ₦48 billion, you must prepare a country-by-country report showing revenue, profit, number of employees, and tangible assets in each jurisdiction. This is part of the OECD Base Erosion and Profit Shifting (BEPS) initiative that Nigeria has adopted.

Supporting Documentation: Contemporaneous documents created at or near the time of the transaction that support your transfer pricing position. This includes contracts, invoices, pricing analyses, market research, and industry studies.

The FIRS has explicit authority under Section 192(3) to make rules requiring documentation. Currently, documentation must be maintained for a minimum of six years and must be provided to the FIRS upon request. Failure to provide documentation can result in penalties of up to 10% of the adjustment made.

Risk Adjustment and Secondary Adjustments

When the FIRS makes a transfer pricing adjustment, it often addresses not just the primary adjustment but also secondary effects. For example, if the FIRS increases your company's reported income by ₦500 million due to a transfer pricing adjustment, this increases your tax liability. But it may also create "double taxation" if your related party's income in another jurisdiction is also adjusted upward.

Under Nigeria's transfer pricing framework, companies have limited protection against double taxation. While the Nigeria Tax Act 2025 contemplates transfer pricing adjustments "in conformity to arm's length terms," relief for double taxation depends largely on mutual agreement procedures with other countries' tax authorities—a process that can take years and is not guaranteed.

Practical Examples: Real Nigerian Multinational Scenarios and Tax Implications

Case Study 1: The Manufacturing Company Charging Inflated Management Fees

Chinedu's company, Delta Manufacturing Ltd., is a Nigerian subsidiary of a German parent company, Frankfurt Industrial GmbH. Frankfurt owns 100% of Delta and has provided substantial technical expertise and quality control support for Delta's operations.

Frankfurt charges Delta an annual management fee of ₦45 million for these services. Delta's total annual revenue is ₦500 million, meaning the management fee represents 9% of revenue. Delta deducted this entire ₦45 million on its corporate income tax return, reducing its taxable income from ₦80 million to ₦35 million.

When the FIRS conducted a transfer pricing audit, the auditor questioned whether the ₦45 million fee was at arm's length. The auditor researched comparable management fees charged by independent management consulting firms providing similar services to Nigerian manufacturing companies. The comparable fees ranged from 2-4% of revenue, suggesting that an arm's length fee would be ₦10-20 million annually, not ₦45 million.

Chinedu had not prepared a transfer pricing study or obtained a benchmarking analysis to support the ₦45 million fee. The FIRS made an adjustment, reducing the allowable management fee to ₦15 million (3% of revenue), resulting in an additional ₦30 million of taxable income.

Tax Impact Calculation:

Before FIRS Adjustment:

• Reported Taxable Income: ₦35 million
• Corporate Income Tax (30%): ₦10.5 million

After FIRS Adjustment:

• Adjusted Taxable Income: ₦65 million (₦35M + ₦30M adjustment)
• Correct Corporate Income Tax (30%): ₦19.5 million
• Additional Tax Owed: ₦9 million
• Penalties (10% of adjustment): ₦3 million
• Interest (8% annually for 3-year review period): ₦2.16 million
• Total Cost of Non-Compliance: ₦14.16 million

Chinedu could have avoided this entire situation with proper transfer pricing documentation prepared before filing his tax return. A transfer pricing study demonstrating that the management fee was based on a comparable analysis supporting the fee at a reasonable level would have provided defensibility.

Case Study 2: The Below-Market Interest Rate on Inter-Company Loan

Amina is the managing director of Prosperity Tech Solutions, a Nigerian software company owned 80% by a South African private equity firm, Joburg Partners. In 2023, Joburg Partners provided a ₦200 million shareholder loan to Prosperity Tech to fund expansion.

Amina structured the loan with a 2% annual interest rate, payable to Joburg Partners. At this rate, Prosperity Tech would pay ₦4 million in annual interest. This seemed reasonable because Amina knew that bank financing was expensive in Nigeria, with rates ranging from 11-18%, and she wanted to minimize interest costs.

When Prosperity Tech filed its 2023 tax return, it deducted the ₦4 million in interest expense.

The FIRS's transfer pricing audit challenged the 2% interest rate. The FIRS's position was that a loan from a related party should reflect the interest rate that the borrower would pay for comparable third-party financing. Given Prosperity Tech's financial profile and the prevailing interest rate environment in Nigeria, a comparable third-party rate would be approximately 14%.

If the interest rate should have been 14% instead of 2%, the correct annual interest would have been ₦28 million, not ₦4 million. This creates a ₦24 million adjustment to Prosperity Tech's taxable income.

Tax Impact Calculation:

Deduction Claimed:

• Interest at 2%: ₦4 million

Correct Deduction (at arm's length rate of 14%):

• Interest at 14%: ₦28 million

FIRS Adjustment:

• Reduction in allowed deduction: ₦24 million
• Increase in taxable income: ₦24 million

Tax Consequences:

• Additional CIT at 30%: ₦7.2 million
• Penalties at 10%: ₦2.4 million
• Interest charges: ₦1.73 million
• Total Additional Tax Cost: ₦11.33 million

Amina's mistake was not having a transfer pricing analysis of the loan terms. Even a simple benchmarking study identifying comparable lending rates in Nigeria would have demonstrated that 2% was not arm's length. An arm's length rate of 7-9% might have been defensible, which would have reduced the impact significantly.

Case Study 3: Intellectual Property Licensing at Minimal Royalty Rate

Olumide owns TechBridge Nigeria, a Nigerian subsidiary of a UK technology company, InnovateTech plc. InnovateTech licenses its proprietary software platform to TechBridge, which resells the software to Nigerian corporate clients.

TechBridge pays InnovateTech a royalty of 3% of software revenues for the software license. TechBridge's 2024 software revenues were ₦600 million, so the royalty paid was ₦18 million.

When the FIRS reviewed TechBridge's transfer pricing documentation, auditors challenged whether 3% was an arm's length royalty rate. The FIRS's analysis showed that:

1. Similar proprietary software platforms licensed to independent businesses in Nigeria typically commanded royalty rates of 8-12%
2. TechBridge provided significant technical support, implementation services, and customer support that substantially increased the value of the software
3. InnovateTech's software was critical to TechBridge's business model and profitability

Based on this analysis, the FIRS determined that an arm's length royalty rate should be 9%, not 3%. This created a ₦36 million difference in royalty payments (9% × ₦600M = ₦54M versus 3% × ₦600M = ₦18M).

Tax Impact:

Claimed Royalty Deduction:

• Royalty at 3%: ₦18 million

Correct Royalty Deduction (at arm's length rate of 9%):

• Royalty at 9%: ₦54 million

FIRS Adjustment:

• Increase in allowed deduction: ₦36 million
• Decrease in taxable income: ₦36 million

Tax Benefit:

• Additional CIT deduction at 30%: ₦10.8 million
• Olumide actually received a tax benefit in this case

However, the converse was also true: InnovateTech's UK tax authorities would argue that TechBridge should have paid a higher royalty rate, potentially resulting in transfer pricing adjustments in the UK. This illustrates the risk of double taxation in transfer pricing disputes—Nigeria's adjustment benefited TechBridge but created challenges for InnovateTech in the UK.

Frequently Asked Questions About Transfer Pricing in Nigeria

Q1: How do I know if my company qualifies as "connected" under Nigerian transfer pricing rules?

You are connected if you have the ability to control or influence the other party's financial, commercial, or operational decisions, either directly or through a third party. This includes ownership stakes, representation on boards, ability to approve expenditures, or shared management. Even minority ownership (e.g., 30%) can establish connection if it translates to influence. The test is about control and influence, not just majority ownership. If you're unsure, consult with a transfer pricing specialist who can analyze your specific ownership and governance structure.

Q2: What's the difference between a "master file" and a "functional transfer pricing study"?

A master file provides group-level information about your multinational enterprise's organization, business model, intangible assets, inter-company financing, and transfer pricing policies. It's a company-level document. A functional transfer pricing study focuses on a specific transaction or group of similar transactions, analyzing comparables and justifying the transfer price for that transaction. You need both: the master file provides context, while the functional study provides transaction-specific support.

Q3: Can I use prices from an online database or industry report to support my transfer pricing position?

Yes, but with caution. You can use publicly available data from industry databases, academic research, and government sources. However, the data must be relevant to your specific circumstances—industry, function, geography, and time period must match. Generic data without specific adjustments for your company's unique characteristics may not satisfy the FIRS. Most companies use a combination of data sources: comparable company analysis, comparable transaction analysis, and cost-plus markup studies, all tailored to their specific situation.

Q4: What happens if I disagree with the FIRS's transfer pricing adjustment?

You can appeal through Nigeria's tax dispute resolution system. Under the Nigeria Tax Act 2025, you can initially object to the FIRS's assessment, then proceed to the Tax Appeal Tribunal if objection is unsuccessful. You'll need strong transfer pricing documentation and expert analysis to successfully defend your position. The burden of proof in Nigerian tax appeals is on the taxpayer, so compelling evidence is essential. Alternative dispute resolution mechanisms, such as mutual agreement procedures with other countries' tax authorities, are available for cases involving double taxation.

Q5: If my group's revenue is below ₦48 billion, do I still need transfer pricing documentation?

Yes. Section 192 of the Nigeria Tax Act 2025 applies to all companies with arrangements involving related parties, regardless of size. While country-by-country reporting is required only for groups with revenue exceeding ₦48 billion, all companies must ensure transactions are at arm's length and must report them to the FIRS. Smaller companies might prepare less extensive documentation, but some documentation is required. A transfer pricing study supporting your position is critical protection regardless of your company's size.

Q6: Can I be penalized if my transfer pricing position was made in good faith but the FIRS disagrees?

Good faith is not a complete defense against penalties in Nigeria's transfer pricing regime. The primary penalty is the tax adjustment itself. However, you can face additional penalties of up to 10% of the adjustment if you fail to provide documentation or if your documentation is inadequate. If you can demonstrate that you made a genuine effort to comply with arm's length principles and documented that effort properly, you may have grounds to dispute penalty assessments, but the tax adjustment itself likely stands.

Q7: How often should I update my transfer pricing documentation?

You should update transfer pricing documentation annually before filing your tax return, or whenever significant business changes occur. If your transfer prices remain consistent, you may be able to use updated comparables analyses rather than preparing entirely new studies. However, changes in business functions, assets, risks, market conditions, or relationships require fresh analysis. It's good practice to review your transfer pricing documentation each year to ensure it remains accurate and defensible.

Action Plan: How to Establish Transfer Pricing Compliance Right Now

Step 1: Identify All Related Party Transactions (Week 1-2)

Conduct a comprehensive review of every transaction between your company and related parties. This includes sales, purchases, service agreements, inter-company loans, royalty arrangements, rent payments, insurance coverage, and any other commercial dealings. Create a detailed list identifying:

• The related party (name, country, ownership stake, nature of relationship)
• The transaction type (goods, services, financing, IP, etc.)
• The annual transaction amount
• The current terms and pricing
• Supporting documentation that currently exists

Assign a specific team member or external advisor to lead this review. Many companies discover undocumented related party transactions during this exercise—transactions that have been occurring without proper transfer pricing analysis.

Step 2: Assess Your Transfer Pricing Risk Profile (Week 2-3)

For each significant related party transaction, assess whether your current pricing is defensible. High-risk transactions typically include:

• Inter-company loans with interest rates below 5% or above 20%
• Management fees representing more than 5% of revenue
• Royalty rates for IP licensing below 3% or above 15%
• Service charges not supported by documented costs
• Asset sales or leases at prices significantly different from market prices

If your related party transactions fall into high-risk categories or lack supporting documentation, prioritize them for transfer pricing analysis. This focused approach allows you to address the highest-risk items first while planning studies for lower-risk transactions.

Step 3: Engage Transfer Pricing Specialists (Week 3-4)

Contact transfer pricing professionals to prepare documentation for material related party transactions. Provide them with:

• Complete details of each transaction
• Your company's financial statements
• Contracts governing the transactions
• Details about the related parties and their functions
• Information about your industry and market conditions

Ask specialists to prepare a functional transfer pricing study for each material transaction category. The study should include:

• Functional analysis of all parties
• Comparable company analysis identifying similar transactions
• Selection of the appropriate transfer pricing method
• Benchmarking analysis supporting your pricing
• Documentation of the analysis and conclusions

Step 4: Document Your Transfer Pricing Position (Week 4-5)

Prepare a master file documenting your group's organization, business model, key intangible assets, inter-company financing arrangements, and overall transfer pricing policies. This provides the foundation for your transaction-specific analyses.

Ensure all documentation is contemporaneous—prepared at or near the time of the transaction, not retroactively. The FIRS is more likely to accept documentation created before filing your tax return than documentation prepared after an audit commences.

Step 5: File Your Tax Return with Transfer Pricing Disclosure (Week 5-6)

When filing your company's annual corporate income tax return, include a disclosure of related party transactions and your transfer pricing position. Reference your transfer pricing documentation and provide a summary of your analysis.

Maintain complete documentation files for at least six years. Organize documentation by transaction type for easy retrieval if the FIRS requests it.

Step 6: Establish Ongoing Compliance Procedures (Ongoing)

Establish an annual process for reviewing transfer pricing arrangements. Before filing each year's tax return:

• Review whether transaction terms have changed
• Update benchmarking analyses with current market data
• Assess whether your transfer pricing methods remain appropriate
• Update functional analyses if business operations have changed
• Ensure all supporting documentation is organized and accessible

This ongoing approach prevents the common situation where companies file one year's return with transfer pricing documentation, then file subsequent years' returns without updating analysis to reflect changed circumstances.

Key Takeaways and Strategic Summary

Transfer pricing compliance under Section 192 of the Nigeria Tax Act 2025 is not optional for multinational enterprises with related party transactions. The FIRS has explicit statutory authority to adjust any transaction it deems not to be at arm's length, and the penalties for inadequate documentation are substantial.

The core requirement is simple: ensure all related party transactions are priced as if the parties were independent entities dealing at arm's length under comparable circumstances. The execution is complex: you must conduct functional analyses, identify comparable transactions, select appropriate transfer pricing methods, and document your analysis thoroughly.

Companies that approach transfer pricing proactively—preparing documentation before filing their tax returns, conducting genuine comparability analyses, and maintaining organized records—demonstrate good faith compliance and significantly reduce audit risk. Companies that treat transfer pricing as an afterthought or ignore it entirely expose themselves to substantial tax adjustments, penalties, and reputational damage.

The investment in professional transfer pricing documentation is modest compared to the cost of defending against FIRS challenges or paying unexpected tax adjustments. For any multinational enterprise in Nigeria, transfer pricing documentation is not a luxury; it's essential business infrastructure.

Related Resources and Tools

For additional support with transfer pricing compliance, explore these TaxEase resources:

• Corporate Income Tax Calculator - Calculate your adjusted tax liability after transfer pricing adjustments
• Inter-Company Loan Interest Rate Benchmark Tool - Determine arm's length interest rates for related party financing
• Transfer Pricing Documentation Checklist - Comprehensive guide to assembling compliant transfer pricing records
• Related Party Transaction Tracker - Maintain organized records of all connected party arrangements

Consider scheduling a consultation with TaxEase's transfer pricing specialists to review your company's specific arrangements and ensure full compliance with Nigerian regulations.