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The Federal Inland Revenue Service (the FIRS) on 27 November 2024 issued an information circular publishing the Guidelines on Advance Pricing Agreements (the APA Guidelines or the Guidelines) with an effective date of 1 January 2025. The APA Guidelines aim to guide taxpayers, tax practitioners, and the public on the procedure and conditions for negotiating and executing Advance Pricing Agreements (APAs) in Nigeria and the administration of executed APAs.
Prior to the issuance of the APA Guidelines, there was no effective legal or administrative framework for APAs in Nigeria. While Regulation 9 of the Income Tax (Transfer Pricing) Regulations 2018 (the TP Regulations) provides the legal framework for APAs, this provision of the TP Regulations was made to come into force upon the publication by the FIRS of relevant Notices and Guidelines.[1] The issuance of the APA Guidelines by the FIRS therefore activates the legal framework under Regulation 9 of the TP Regulations and provides for the administrative framework for APAs in Nigeria.
This article provides an overview of the APA Guidelines, examines possible challenges to implementation, and the concurrence of the Guidelines with global standards.
Click here to download and read the full publication.
Should you have any questions regarding this article series, please do not hesitate to contact Agbada Agbada.
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