Transfer Pricing Framework™
Defensible TP policy, documentation and benchmarking for Nigerian groups.
What it is.
A documentation-first TP framework covering the NRS TP Regulations, OECD Guidelines and BEPS 2.0 — turning related-party flows into auditable, benchmarked and disclosed positions.
- Maintain a current Master File, Local File and CbCR notification.
- Set arm's-length policies for goods, services, royalties, intra-group financing and management fees.
- Document benchmarking and economic analysis to NRS standards.
- Defend positions in TP audits and TAT cases.
Functional analysis
Map related-party transactions, value drivers and DEMPE positions.
Policy design
Set arm's-length methods, mark-ups and intra-group agreements.
Benchmarking
Run benchmark studies and document economic analysis.
Documentation & filing
Produce Master File, Local File and TP disclosures on the NRS portal.
Scope
- Transaction matrix completed
- Methods agreed
Document
- Master File and Local File drafted
File & defend
- TP disclosure filed
- Audit-defence pack ready
Related across the Tax Centre
Transfer Pricing Documentation Toolkit
Master File and Local File templates, benchmarking workbook and CbCR checklist aligned to the NRS TP Regulations and OECD Guidelines.
BEPS 2.0 Practical Guide for Nigerian Groups
How Pillar One and Pillar Two reshape the tax bill for Nigerian groups with cross-border footprint — with a readiness diagnostic.
Tax Readiness Score™
10-question interactive transition diagnostic — measure your readiness for the 2026 Tax Acts and the Nigeria Revenue Service regime.
Tax Excellence Certification™
Certify a tax function ready for the Nigerian Tax Act 2025 and the NRS era.
Tax Advisory
Structuring, compliance and controversy across the full Nigerian tax stack.