Taxation Law, Ict And Telecommunication Law And Cybersecurity And Data Protection Law
Assistant Lecturer
Business Law
At the Business Law department office
Appointment on Visitation important
| # | Certificate | School | Year |
|---|---|---|---|
| 1. | LL. M. (TAXATION) | LAGOS STATE UNIVERSITY, OJO LAGOS | 2024 |
A COMPARATIVE LEGAL ANALYSIS OF TRANSFER PRICING REGULATIONS IN NIGERIA AND OECD COUNTRIES
Transfer pricing has become a critical issue in international taxation due to the increasing volume of cross-border transactions involving multinational enterprises (MNEs). The allocation of income and expenses among related entities operating across different jurisdictions presents significant challenges for tax authorities, particularly in developing economies such as Nigeria. This study undertakes a comparative legal analysis of transfer pricing regulations in Nigeria and selected OECD countries, with a view to examining the adequacy, effectiveness, and consistency of the respective legal and regulatory frameworks. The study critically analyses Nigeria’s transfer pricing legislation, regulations, administrative practices, and dispute resolution mechanisms against relevant OECD standards, including the OECD Transfer Pricing Guidelines and the arm’s length principle. It further examines areas of convergence and divergence in relation to documentation requirements, comparability analysis, intra-group transactions, advance pricing arrangements, dispute resolution, enforcement, and penalties. The study adopts a doctrinal and comparative legal research methodology, complemented where appropriate by relevant empirical and policy materials. It argues that although Nigeria has progressively strengthened its transfer pricing framework, significant legal and institutional challenges remain in achieving effective administration, taxpayer certainty, and protection of the Nigerian tax base. The study proposes legal and regulatory reforms capable of enhancing compliance, reducing transfer pricing disputes, and aligning Nigeria’s framework with evolving international tax standards while reflecting its domestic economic realities.
Keywords: Transfer Pricing, Nigeria, OECD International Taxation, Arm’s Length Principle, Multinational Enterprises
ASHIMI SELOME is a Assistant Lecturer at the Department of Business Law
ASHIMI has a LL. M. in TAXATION from LAGOS STATE UNIVERSITY, OJO LAGOS