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Nigeria issues Guidelines on Advance Pricing Agreements

20 December 2024

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Tax Alerts, National/Federal Taxation, Transfer Pricing, Global

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Nigeria

Nigeria has introduced Guidelines on Advance Pricing Agreements (APAs).The guidelines activate the APA provisions contained in the Income Tax (Transfer Pricing) Regulations 2018 and shall take effect from 1 January 2025.Taxpayers engaged in intercompany transactions that meet the required threshold annually can apply.APAs have a maximum duration of three years and may be renewed upon expiration.The guidelines allow for a rollback of the agreed APA methodology to a maximum of three prior years based on meeting certain conditions. Executive summaryThe Nigeria Federal Inland Revenue Service (FIRS) issued the Guidelines on Advance Pricing Agreements (APA Guidelines or the Guidelines) on 27 November...