Nigeria has issued the Income Tax (Country-by-Country Reporting) Regulations 2018 (the CbCR Regulations) which are part of the implementation plans under Action 13 of OECD’s Base Erosion and Profit Shifting (BEPS) project.
The initiative is in furtherance of Nigeria’s signing of the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Country-by-Country reports in January 2016. The Federal Executive Council (FEC) ratified the reports in August 2016.
Specifically, the CbCR Regulations provide guidance to multinational enterprises (MNEs) on their reporting obligations to Federal Inland Revenue Service (FIRS) in relation to their group income, taxes paid, and other indicators of their group economic activity.
The information collected will enable the Service perform high-level transfer pricing risk assessment as well as evaluate other BEPS related risks.
Analysts believe that the issuing of the CbCR Regulations demonstrates the Federal Government’s resolve to curb tax avoidance schemes and profit shifting in Nigeria.
Expectedly, the CbCR Regulations will also empower the Service to put in place adequate frameworks and mechanisms that will enable it collaborate with the revenue authorities of other tax jurisdictions in fighting BEPS.