Remunerating Transactions Involving Intangibles – Learnings from a Recent Transfer Pricing Audit Outcome in Nigeria

Abstract

There is an ongoing wave of transfer pricing audits in Nigeria at the moment, with the tax authorities scrutinizing big-ticket related-party transactions, often with a transfer pricing adjustment as the outcome. This article discusses aspects of a recent transfer pricing audit case, with a focus on intangibles, and highlights what taxpayers need to know in preparing a defence, as well as providing viable solutions for when there is divergence of opinions between the taxpayer and the tax administration.