Defensible Pricing.
At Arm's Length.
Comprehensive transfer pricing advisory that ensures your intercompany transactions are properly documented, compliant, and defensible before Nigerian and international tax authorities.
Transfer Pricing Done Right
Transfer pricing is one of the most scrutinised areas of Nigerian taxation. The NRS (Nigeria Revenue Service) has significantly stepped up audit activity, and organisations without proper documentation face substantial penalties and reputational risk.
Our transfer pricing team combines deep technical knowledge of the OECD Guidelines and Nigerian regulations with practical experience navigating NRS audits — giving you the confidence that your intercompany transactions are properly structured and defended.
We work across all transaction types — goods, services, intellectual property, financial transactions, and cost-sharing arrangements — ensuring every element of your group's pricing model is compliant and documented.
“Proper transfer pricing documentation is not just a compliance exercise — it is your first line of defence in any audit.”
— SON Professional Services
Transfer Pricing Policies, Planning and Documentation
We design robust transfer pricing policies and prepare comprehensive documentation that meets NRS (Nigeria Revenue Service) requirements and international standards, protecting your organisation from penalties.
Transfer Pricing Compliance Support Services
Ongoing compliance monitoring and filing support to ensure your intercompany transactions remain aligned with arm's length principles throughout the year.
Transfer Pricing Risk Analysis and Controls
We identify and quantify transfer pricing risks across your group structure, implementing controls that strengthen your compliance posture before regulators come calling.
Transfer Pricing Audit Support
Expert representation and technical support during NRS (Nigeria Revenue Service) transfer pricing audits — helping you present a defensible position and achieve the best possible outcome.
Transfer Pricing and NOTAP Alignment
We align your transfer pricing arrangements with NOTAP (National Office for Technology Acquisition and Promotion) registration requirements to avoid disallowances and penalties.
Advanced Pricing Arrangements
We negotiate advance pricing arrangements (APAs) with tax authorities on your behalf, providing certainty over the tax treatment of your intercompany transactions going forward.