Arm’s Length – Knowsia

ATAX – May 2019 – L3 – Q6 – Transfer Pricing

Outline key aspects of transfer pricing regulations in Nigeria, including objectives, key concepts, and methods.

Question

The need for monitoring and controlling the operations of multi-national enterprises (MNEs) and their local subsidiaries or associate companies around the world has necessitated special interest in various governments putting in place mechanisms for the treatment of transfer pricing. Although transfer pricing is not new in Nigeria, the law regulating it, the Income Tax (Transfer Pricing) Regulation Act, was enacted in August 2012. It specifies that “every taxpayer” is expected to develop a transfer pricing policy in regard to transfer pricing and control transactions, as well as treatment of transactions of permanent establishments (PE) and dispute resolutions.

You have been invited by the Nigerian Association of Chambers of Commerce, Industry, Mines and Agriculture (NACCIMA) to present a paper at a workshop on transfer pricing regulations in Nigeria. The primary objective of the workshop is to provide the participants, both local and foreign stakeholders in the Nigerian business environment, necessary information on transfer pricing issues in Nigeria.

You are required to outline relevant points to address the following issues:

a. Objectives of application of transfer pricing regulation in Nigeria (3 Marks)
b. The concepts of:
i. Connected taxable persons (3 Marks)
ii. Arm’s length principle (3 Marks)
c. Description of three transfer pricing methods (6 Marks)

Answer

Find Related Questions by Tags, levels, etc.

Tags: Arm's Length, Nigerian Tax Law, Taxable Persons, Transfer Pricing, Transfer Pricing Methods
Level: Level 3

Topic: Transfer Pricing

AT – Nov 2019 – L3 – Q3b – International Taxation

Recommend and justify the most suitable transfer pricing method for Pyrotechnics Ghana Limited.

Question

Pyrotechnics Ghana Limited was established for the main purpose of providing marketing support services to Pyrotechnics UK Limited, its parent company. Pyrotechnics Ghana Limited’s expenses are reimbursed with a 5% mark-up, which constitutes its total revenue.

Required:

What is the best transfer pricing method that can be used to test this transaction? Justify your response and show how the method will be applied.

Answer

Find Related Questions by Tags, levels, etc.

Tags: Arm's Length, Multinational Enterprises, Transactional Net Margin Method (TNMM), Transfer Pricing
Level: Level 3

Topic: International taxation
Series: NOV 2019

ATAX – May 2019 – L3 – Q6 – Transfer Pricing

Outline key aspects of transfer pricing regulations in Nigeria, including objectives, key concepts, and methods.

Question

You are required to outline relevant points to address the following issues:

Answer

Find Related Questions by Tags, levels, etc.

Tags: Arm's Length, Nigerian Tax Law, Taxable Persons, Transfer Pricing, Transfer Pricing Methods
Level: Level 3

Topic: Transfer Pricing

AT – Nov 2019 – L3 – Q3b – International Taxation

Recommend and justify the most suitable transfer pricing method for Pyrotechnics Ghana Limited.

Question

Required:

What is the best transfer pricing method that can be used to test this transaction? Justify your response and show how the method will be applied.

Answer

Find Related Questions by Tags, levels, etc.

Tags: Arm's Length, Multinational Enterprises, Transactional Net Margin Method (TNMM), Transfer Pricing
Level: Level 3

Topic: International taxation
Series: NOV 2019

Question Tag: Arm's Length

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ATAX – May 2019 – L3 – Q6 – Transfer Pricing

Outline key aspects of transfer pricing regulations in Nigeria, including objectives, key concepts, and methods.

AT – Nov 2019 – L3 – Q3b – International Taxation

Recommend and justify the most suitable transfer pricing method for Pyrotechnics Ghana Limited.

ATAX – May 2019 – L3 – Q6 – Transfer Pricing

Outline key aspects of transfer pricing regulations in Nigeria, including objectives, key concepts, and methods.

AT – Nov 2019 – L3 – Q3b – International Taxation

Recommend and justify the most suitable transfer pricing method for Pyrotechnics Ghana Limited.

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ATAX – May 2019 – L3 – Q6 – Transfer Pricing

Outline key aspects of transfer pricing regulations in Nigeria, including objectives, key concepts, and methods.

You're reporting an error for "ATAX – May 2019 – L3 – Q6 – Transfer Pricing"

AT – Nov 2019 – L3 – Q3b – International Taxation

Recommend and justify the most suitable transfer pricing method for Pyrotechnics Ghana Limited.

You're reporting an error for "AT – Nov 2019 – L3 – Q3b – International Taxation"

ATAX – May 2019 – L3 – Q6 – Transfer Pricing

Outline key aspects of transfer pricing regulations in Nigeria, including objectives, key concepts, and methods.

You're reporting an error for "ATAX – May 2019 – L3 – Q6 – Transfer Pricing"

AT – Nov 2019 – L3 – Q3b – International Taxation

Recommend and justify the most suitable transfer pricing method for Pyrotechnics Ghana Limited.

You're reporting an error for "AT – Nov 2019 – L3 – Q3b – International Taxation"

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Customer

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