Recently, as part of LeLaw's Nigerian country chapter contribution to Bloomberg’s Winter 2020/Spring 2021: Transfer Pricing Forum, (Bloomberg Publication), we used TP lenses to look closely at the Companies and Allied Matters Act 2020 (CAMA). It was an interesting exercise that revealed the complementariness of CAMA’s provisions to that of the Income Tax (Transfer Pricing) Regulations 2018 (TPRs 2018), that is the bulwark of Nigeria’s TP regime. It is saying the obvious that Nigeria’s TP regime was until recently, stuck at its basic state – prompting calls by commentators for requisite regulatory actions.5 Happily, the TPRs 2012, Nigeria’s inaugural TP focused instrument, was issued thereafter in August 2012, to much acclaim.
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