Nigeria Transfer Pricing (TP) Audit Experience

It is no surprise that over the past year the FIRS has embarked on an intensive transfer pricing (TP) audit drive. After two years of sensitizing the public about the implementation of the Nigeria TP Regulations; gathering of taxpayers’ documents through requests for TP policies and filing of TP returns; and ramping up of its TP division’s capacity and capability, the FIRS is now ready and out to generate the much needed tax revenue through TP investigations, adjustments and assessments.

Considering that TP audits are significantly different from normal tax audits, taxpayers faced significant uncertainties as to how the FIRS was going to approach the TP audit process. Fortunately, with our TP audit experience from other tax jurisdictions, we have been able to assist our clients navigate this laborious and uncertain process.

Further, TP audit/investigation can be very challenging for taxpayers, as mismanagement of the process can lead to prolonged reconciliation meetings and increased tax liabilities. Therefore, proactive management of the exercise is very important. This TP training seeks to equip taxpayers with the practical knowledge and skills required to adequately manage TP audits from start to finish.

The program will focus on some of the following practical experiences and key concepts:

  • Highlight FIRS’ current approach to TP pre-audit, desk audit and field audit
  • Emphasize key areas of TP exposure during a TP audit process based on our experience with the FIRS
  • Refresher on understanding the TP audit process – From TP risk assessment to TP dispute resolution
  • Refresher on managing the pre-audit, field audit and post- audit stages of TP audit and/or
  • Refresher on how to proactively plan for TP audit and/or
  • Refresher on how to facilitate speedy close-out of TP
In delivering the training, we will use various instructional modes, such as:
  • Sharing our experience from ongoing FIRS TP audits
  • Instructor-led structured discussions, and practical applications directed at real-life
  • Practical learner-centred approach with emphasis on transfer of learning to participants
  • Case studies and mini quizzes to boost participants’ understanding of various tips for managing tax audit/ investigation
Target Participants

Tax Controllers and Managers, Finance Controllers and Managers, Legal Officers and Managers and related functions with responsibility for tax and commercial compliance and administration.

Course Duration & Fee

This program is scheduled to run for a working day. The fee for the training is N100,000 per participant (exclusive of VAT). The fee covers tuition, course materials, lunch and refreshments.

We offer group discount of 5% for 2 to 4 participants and 10% discount for 5 or more participants.
*Attendance of the programme is subject to KPMG’s approval.






Nigeria Transfer Pricing (TP) Audit Experience


David Okwara

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