Nigeria's Income Tax (Transfer Pricing) Regulations 2018

Conceptualizing the Elephant and “Plucking the Goose”

Bibliographic Data

ID16767415
AuthorsIfeanyichukwu Azuka Aniyie (0000-0002-9524-829X, Afe Babalola University, corresponding author), Osamuyimen Enabulele (0000-0002-1068-0244, corresponding author)
Year2020
Volume64
Issue2
Pages267-286
Publication date2020-06-01
Peer ReviewedYes
Open AccessYes
TypeARTICLE
VenueJournal of African Law (JOURNAL)
Journal identifiersISSN: 0221-8553 • E-ISSN: 1464-3731
PublisherCambridge University Press (PUBLISHER • US)
DOI10.1017/s0021855320000108
OpenAlexW3024462060
LanguageEN
References cited23

In 2015, the OECD gave the world a template to address base erosion and profit shifting and ensure that profit is taxed in the jurisdiction of value addition and / or where economic activities take place. The world's jurisdictions then embarked on implementing the template. Examining the legal framework subsequently put in place for the taxation of intangibles in Nigeria, this article argues that the distinct regimes for connected and unconnected persons’ transactions create flaws. It further asserts that these flaws are consequences of the conflict between the policy that underpins the legal framework and other policies in the country. It concludes that the legal framework may not be a “Swiss army knife” (providing Nigeria with all that is needed to combat transfer pricing issues associated with the transfer of intangibles by connected persons), as it creates issues that have undesired consequences for the taxation as well as the economic system

Base erosion and profit shifting · Business · Economics · International taxation · Jurisdiction · Microeconomics · Political science · Profit (economics) · Public economics · Tax reform · Transfer pricing · Corporate Taxation and Avoidance · Finance · Fiscal Policy and Economic Growth · Law · Taxation and Compliance Studies

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