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Nigeria's Tax Appeal Tribunal Issues First Ruling on Transfer Pricing

02 March 2020

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Approved Changes

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Nigeria

Nigeria's Tax Appeal Tribunal has reportedly issued its first ruling in respect of transfer pricing. The ruling concerns the appropriate transfer pricing method to be applied by a Nigerian company engaged in the plastics and petrochemicals trade, Prime Plastichem Nigeria Ltd. In 2013, Prime Plastichem used the comparable uncontrolled price (CUP) method in determining the arm's length price of its purchase of petrochemical products from an offshore related party. In 2014, the company changed to using the transactional net margin method (TNMM) in determining the arm's length price of the same types of purchases from the related party. In 2016,...