Nigeria’s Federal Inland Revenue Service (FIRS) updated the Income Tax (Transfer Pricing) Regulations, 2018 to include specific criteria that intra-group services must fulfil if they are to be considered as arm’s length and thus tax deductible.

Briefly, companies seeking to claim a tax deduction for intra-group services will need to demonstrate the performance of an actual service which provided economic and commercial benefits to the company. In addition, companies will also need to defend their pricing proving that an independent 3^rd party would have paid a similar price for the services.