In response to this requirement, jurisdictions participating in the BEPS Project agreed on revised standards for transfer pricing documentation and a template for country-by-country reporting of income, taxes paid and certain measures of economic activity. On 16 September 2014, the OECD published the “Guidance on Transfer Pricing Documentation and Country-by-Country Reporting” that provided template for country-by-country reporting.Â
The work on the comprehensive Action Plan on BEPS was concluded in October 2015 and a package of 15 reports delivered, culminating in new or reinforced international standards as well as producing concrete measures to help countries tackle BEPS. One of these measures is the Country-by-Country reporting under Action 13 of the BEPS Project, which is a minimum standard under the BEPS outcomes.
Nigeria is a member of the Inclusive Framework, a group of jurisdictions, committed to the implementation of the minimum standards of the BEPS related measures. Towards this end, Nigeria signed the Multilateral Competent Authority Agreement on Country-by-Country Reporting (CbC MCAA) in January 2016 and has produced the Income Tax (Country-by-Country Reporting) Regulations 2018 (“CbC Regulations”) for the implementation of the Country-by-Country Reporting in Nigeria. Relevant documents required for the implementation of CbC Reporting in Nigeria can be found on this page.â