Assessing the Transfer Pricing Disputes Framework in Nigeria

Abstract

Transfer pricing, from documentation to audit, can be complicated and costly. Despite the release of transfer pricing regulations and increased scrutiny over intercompany dealings, the revenue authorities and taxpayers still disagree over various aspects of transfer pricing documentation. This situation necessitated the creation of various transfer pricing dispute resolution and dispute prevention mechanisms in jurisdictions across the globe. The Organization for Economic Cooperation and Development (OECD) has set the global standards on the mechanisms for transfer pricing dispute resolution/prevention and how they should apply. These transfer pricing dispute prevention mechanisms seek to avoid the costly and complicated process that is associated with transfer pricing audit while the transfer pricing dispute resolution mechanisms seek to resolve transfer pricing disputes in the most efficient manner. Accordingly, this article seeks to assess the transfer pricing dispute resolution/prevention framework in Nigeria against the global standards for resolving and preventing transfer pricing disputes. Transfer pricing, safe harbour, advanced pricing arrangement, mutual agreement procedure, dispute resolution, dispute prevention