Nigeria has met the terms of reference (ToR) for the calendar year 2017 (year in review) that can be met in the absence of rulings being issued.
Nigeria does not issue any type of ruling within the scope of the transparency framework. Nigeria issues rulings on the tax consequences of a transaction which are binding for the tax authorities. However, the rulings issued by Nigeria do not relate to a preferential tax regime, determine or decide on the existence or the absence of a permanent establishment or provide for how much profit will be attributed to a permanent establishment, advance pricing arrangements, downward adjustment or a conduit ruling and are therefore not considered rulings as defined in the Action 5 report (OECD, 2015). In the event that Nigeria puts in place the administrative process to issue rulings within the scope of the transparency framework, Nigeria notes that it would implement the transparency framework obligations.
As there were no rulings issued, no exchange of information was required. Therefore, no peer input was received in respect of exchanges of information on rulings received from Nigeria.