All Countries
International Trade
Transfer Pricing Agreement

Transfer Pricing Agreement Template for Nigeria

Create a bespoke document in minutes,  or upload and review your own.

4.6 / 5
4.8 / 5

Let's create your Transfer Pricing Agreement

Thank you! Your submission has been received!
Oops! Something went wrong while submitting the form.

Get your first 2 documents free

Your data doesn't train Genie's AI

You keep IP ownership of your information

Key Requirements PROMPT example:

Transfer Pricing Agreement

"I need a Transfer Pricing Agreement between our Nigerian manufacturing subsidiary and UAE parent company for the production and supply of automotive parts, ensuring compliance with Nigerian regulations and including specific provisions for technology transfer fees starting March 2025."

Celebrated by
Collaborations with
Investors
Document background
A Transfer Pricing Agreement is essential for related entities conducting business in Nigeria to establish compliant pricing mechanisms for their intercompany transactions. This document becomes necessary when companies within the same group engage in cross-border or domestic related-party transactions involving goods, services, intellectual property, or financing arrangements. The agreement must align with Nigeria's Income Tax (Transfer Pricing) Regulations 2018, which follows OECD guidelines and requires strict documentation and compliance procedures. It is particularly crucial given the Nigerian Federal Inland Revenue Service's increased scrutiny of transfer pricing arrangements and the significant penalties for non-compliance. The agreement helps demonstrate to tax authorities that transfer prices are set at arm's length and provides a framework for maintaining required documentation.
Suggested Sections

1. Parties: Identification of the related entities entering into the agreement, including registration details and tax identification numbers

2. Background: Context of the relationship between parties and purpose of the agreement

3. Definitions: Key terms used in the agreement, including technical transfer pricing terminology

4. Scope of Agreement: Description of transactions covered, including goods, services, or intellectual property

5. Transfer Pricing Methodology: Detailed explanation of the chosen pricing method(s) and justification for selection

6. Pricing Terms: Specific pricing mechanisms, calculations, and adjustments

7. Documentation Requirements: Records to be maintained to comply with Nigerian Transfer Pricing Regulations

8. Compliance Obligations: Parties' obligations regarding regulatory compliance and reporting

9. Term and Termination: Duration of the agreement and circumstances for termination

10. Representations and Warranties: Standard warranties regarding capacity, authority, and compliance

11. Dispute Resolution: Procedures for resolving disagreements and jurisdiction clause

12. General Provisions: Standard boilerplate clauses including notices, amendments, and governing law

Optional Sections

1. Advance Pricing Agreement Provisions: Include when parties seek to establish an APA with Nigerian tax authorities

2. Industry-Specific Provisions: Additional terms for specific sectors (e.g., oil and gas sector under PPTA)

3. Customs Valuation: Include for agreements involving cross-border transfer of physical goods

4. Intellectual Property Rights: Include when agreement covers IP licensing or transfers

5. Cost Sharing Arrangements: Include when parties share development costs or services

6. Force Majeure: Include when parties want specific provisions for unforeseen circumstances

7. Language: Include when parties operate in multiple languages to specify controlling language

Suggested Schedules

1. Schedule A - Covered Transactions: Detailed list and description of all controlled transactions covered by the agreement

2. Schedule B - Pricing Methodology Details: Detailed calculations, formulas, and examples of how transfer prices will be determined

3. Schedule C - Functional Analysis: Analysis of functions performed, risks assumed, and assets employed by each party

4. Schedule D - Documentation Requirements: Specific list of required documentation and maintenance procedures

5. Schedule E - Comparability Analysis: Details of comparable transactions or entities used in pricing methodology

6. Appendix 1 - Compliance Calendar: Timeline for various compliance and reporting obligations

7. Appendix 2 - Related Party Information: Detailed information about all related parties involved in the agreement

8. Appendix 3 - Financial Adjustments: Procedures and formulas for making periodic adjustments to transfer prices

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Linkedin in social icon imageX social icon image
alex.den.21@genieai.co
Relevant legal definitions
Arm's Length Principle
Associated Enterprise
Comparable Uncontrolled Price
Connected Person
Controlled Transaction
Cost Plus Method
Documentation Requirements
FIRS
Group
Income Tax (Transfer Pricing) Regulations
Intangible Property
Inter-company Transaction
Management Services
Market Price
OECD Guidelines
Parent Company
Permanent Establishment
Related Party
Resale Price Method
Royalty
Service Fee
Subsidiary
Tax Year
Transfer Price
Transfer Pricing Method
Transactional Net Margin Method
Uncontrolled Transaction
Working Day
Advance Pricing Agreement
Beneficial Ownership
Comparability Analysis
Compliance Documentation
Cost Contribution Arrangement
Functional Analysis
Profit Level Indicator
Risk Assessment
Tested Party
Transaction Value
Value Chain Analysis
Clauses
Interpretation
Scope
Transfer Pricing Methodology
Pricing Adjustments
Documentation Requirements
Regulatory Compliance
Record Keeping
Information Exchange
Confidentiality
Tax Compliance
Audit Rights
Risk Allocation
Force Majeure
Dispute Resolution
Governing Law
Term and Termination
Representations and Warranties
Indemnification
Amendment
Assignment
Notices
Severability
Entire Agreement
Costs and Expenses
Further Assurance
Reporting Obligations
Cooperation
Anti-Bribery and Corruption
Data Protection
Counterparts
Relevant Industries

Oil and Gas

Manufacturing

Telecommunications

Financial Services

Pharmaceuticals

Consumer Goods

Technology

Mining and Extractives

Agriculture

Logistics and Transportation

Professional Services

Real Estate

Relevant Teams

Legal

Finance

Tax

Compliance

Risk Management

International Tax

Corporate Affairs

Treasury

Commercial Operations

Company Secretariat

Relevant Roles

Tax Director

Chief Financial Officer

Transfer Pricing Manager

International Tax Manager

Finance Director

Legal Counsel

Compliance Officer

Group Financial Controller

Tax Compliance Manager

Head of Finance

Commercial Director

Managing Director

Risk Manager

Operations Director

Company Secretary

Industries
Income Tax (Transfer Pricing) Regulations 2018: The primary regulation governing transfer pricing in Nigeria, which replaced the 2012 regulations and provides detailed rules for connected party transactions
Companies Income Tax Act (CITA): The fundamental law governing corporate taxation in Nigeria, including provisions related to related party transactions
Federal Inland Revenue Service (Establishment) Act 2007: Establishes the authority of FIRS to administer and enforce transfer pricing regulations
OECD Transfer Pricing Guidelines: International guidelines that Nigeria's transfer pricing regulations are based on, providing principles for arm's length transactions
Nigerian Transfer Pricing Country-by-Country Reporting Regulations 2018: Specific requirements for multinational enterprises regarding detailed reporting of their global operations
Double Taxation Treaties: Various bilateral agreements between Nigeria and other countries that affect transfer pricing arrangements
Petroleum Profits Tax Act: Specific provisions for transfer pricing in the oil and gas sector, which has special considerations in Nigeria
Value Added Tax Act: Relevant for transfer pricing considerations regarding the valuation of goods and services between related parties
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

Find the exact document you need

Tax Indemnity Agreement

A Nigerian law-governed agreement establishing tax indemnification obligations between parties, including protection against specified tax liabilities and compliance with Nigerian tax regulations.

find out more

Transfer Pricing Agreement

An agreement governing transfer pricing arrangements between related entities in Nigeria, ensuring compliance with local transfer pricing regulations and tax laws.

find out more

Engagement Letter For Tax Services

A Nigerian-compliant professional letter establishing terms and conditions for the provision of tax services between a tax advisory firm and its client.

find out more

Payment Plan Installment Agreement

A Nigerian law-governed agreement establishing structured repayment terms through scheduled installments between a creditor and debtor.

find out more

Direct Debit Installment Agreement

A Nigerian law-governed agreement establishing automated recurring payments from a debtor's account to a creditor through direct debit authorization.

find out more

Bilateral Advance Pricing Agreement

A binding agreement under Nigerian law between FIRS, a foreign tax authority, and a taxpayer establishing agreed transfer pricing methodologies for cross-border transactions.

find out more

Tax Funding Agreement

A Nigerian law-governed agreement establishing tax funding arrangements within corporate groups, including payment mechanisms and compliance requirements.

find out more

Tax Exchange Information Agreement

A bilateral agreement establishing tax information exchange procedures between Nigeria and another jurisdiction, ensuring compliance with Nigerian and international tax transparency standards.

find out more

Tax Consulting Engagement Letter

A Nigerian-compliant engagement letter template for tax consulting services, establishing professional terms and scope between tax consultants and clients.

find out more

Tax Allocation Agreement

A Nigerian law-governed agreement establishing tax revenue allocation mechanisms between governmental entities and authorities.

find out more

Tax Payment Agreement

A legally binding agreement under Nigerian law between a taxpayer and tax authority establishing structured payment terms for outstanding tax liabilities.

find out more

Advance Price Agreement

A binding agreement between a taxpayer and Nigerian tax authorities (FIRS) establishing approved transfer pricing methodologies for related-party transactions.

find out more

Fuel Tax Agreement

A Nigerian law-governed agreement establishing fuel tax obligations and compliance requirements between tax authorities and fuel industry participants.

find out more

Installment Payment Agreement

A Nigerian law-governed agreement establishing terms for structured installment payments between parties, including payment schedules, interest rates, and enforcement provisions.

find out more

Download our whitepaper on the future of AI in Legal

By providing your email address you are consenting to our Privacy Notice.
Thank you for downloading our whitepaper. This should arrive in your inbox shortly. In the meantime, why not jump straight to a section that interests you here: https://www.genieai.co/our-research
Oops! Something went wrong while submitting the form.

Genie’s Security Promise

Genie is the safest place to draft. Here’s how we prioritise your privacy and security.

Your documents are private:

We do not train on your data; Genie’s AI improves independently

All data stored on Genie is private to your organisation

Your documents are protected:

Your documents are protected by ultra-secure 256-bit encryption

Our bank-grade security infrastructure undergoes regular external audits

We are ISO27001 certified, so your data is secure

Organizational security

You retain IP ownership of your documents

You have full control over your data and who gets to see it

Innovation in privacy:

Genie partnered with the Computational Privacy Department at Imperial College London

Together, we ran a £1 million research project on privacy and anonymity in legal contracts

Want to know more?

Visit our Trust Centre for more details and real-time security updates.

Read our Privacy Policy.