In Nigeria, the Federal Inland Revenue Service (FIRS) issued the Income Tax (Country-by-Country Reporting) Regulations, 2018 (CbCR Regulations) on 19 June 2018. This presentation summarises the key provisions and addressed some pertinent questions that companies covered need to understand.

1. Country-by-Country Reporting
Regulations - Nigeria
2018

2. Country-by-Country Reporting Regulations, 2018
Nigeria
Outline
Overview
Threshold
Checklist
Notice period
Frequently asked questions
CbCR regulations, Nigeria - 2018
Penalty for non-compliance

3. Overview
The Federal Inland Revenue Service (FIRS) has
published the Income Tax (Country-by-Country
Reporting) Regulations, 2018 (CbCR Regulations)
on 19 June 2018.
Effective date is 1 January 2018.
*Base Erosion and Profit Shifting
CbCR regulations, Nigeria - 2018 1
Action 13 of
BEPS* Project
Increase
international
tax
disclosure
Lower tax
avoidance
risks

4. Threshold
1
The Ultimate Parent Entity (UPE) or a
Constituent Entity (CE) of a Multinational
Enterprise Group (MNE Group) is tax
resident in Nigeria
2
The Group has a total consolidated
revenue of ₦160,000,000,000 or more in
the immediate preceding accounting year
CbCR regulations, Nigeria - 2018 2

5. Checklist
✓ accumulated
earnings
✓ number of
employees
✓ revenue
✓ profit or loss
before income
tax
✓ income tax paid
or accrued
✓ stated capital
✓ tangible assets
other than cash
or cash
equivalents
Section 7 of the Regulations stipulates that the CbCR for a MNE Group shall
include the following information:
CbCR regulations, Nigeria - 2018 3

6. A qualifying Nigerian tax
resident is required to notify the
FIRS not later than the final day
of the reporting accounting year
of the MNE Group.
Notice Period
CbCR regulations, Nigeria - 2018 4

7. Penalty for non-compliance
1. Failure to file CbCR attracts penalty of ₦10,000,000 and ₦1,000,000 for every month in
which the failure continues.
2. Filing incorrect or false report attracts a penalty of ₦10,000,000.
3. Failure to notify the FIRS of the entity that will file the CbCR within the statutory period
attracts a penalty of ₦5 million and ₦10,000 for every day in which the failure continues.
CbCR regulations, Nigeria - 2018 5

8. CbCR regulations, Nigeria - 2018 6
The FIRS will gather more
information pertaining to
MNE operations. Hence, it
is crucial that MNE Groups
assess their Transfer
Pricing and BEPS risks and
proactively take adequate
steps to resolve them.

9. Frequently asked questions
What class of companies are covered under this regulation?
How can I ascertain if my MNE or UPE is tax resident in Nigeria?
When is the commencement date of CbCR?
My transfer pricing returns are due on 30 June 2018,
will there be an extension to file CbCR?
What happens if I do not comply?
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CbCR regulations, Nigeria - 2018 7

10. Thank you!
For further discussion, please contact
Maureen Omodiagbe
maureen@bomesresourcesconsulting.com
www.bomesresourcesconsulting.com
Stay in touch with us
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