ECOWAS Supplementary Act undergoing the process of making it to enter into force. When in force, it will activate MAP with 14 member countries with effect from 1st January 2024.
Signed an Avoidance of Double Taxation Agreement with Turkey on 20th October 2021, which is consistent with Action 14 Minimum Standard. The treaty has not entered into force.
Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023
OECD/G20 Base Erosion and Profit Shifting Project
Nigeria
Recent developments relating to MAP in Nigeria prior to 15 August 2023
Developments relating to MAP in the tax treaty network
Other developments relating to MAP
Nigeria updated its MAP Guideline and MAP Profile in 2023.
Latest Action 14 Peer Review report
The stage 1 Simplified Peer Review report of Nigeria is expected to be published early 2024.
Tax treaty network of Nigeria
18 treaties, applicable to 31 jurisdictions (covering all treaties signed, although not necessarily in force)
status of MLI: in force.
Table 1. State of play of Nigeria's tax treaty network
Source: OECD
Nigeria's MAP programme
Organisation of competent authority function
11 persons assisting the Competent Authority, comprising:
five heads of functions and six persons working on MAP cases:
out of those 11, six persons work on attribution/allocation cases and five persons work on other cases.
contact persons for MAP requests:
Director, Tax Policy and Advisory Department & Authorized Competent Authority for MAP matters.
Federal Inland Revenue Service, 3rd Floor, Revenue House Annex, 26 Sokode Crescent, Wuse Zone 5, Abuja, FCT, Nigeria. Email: acatreatiesandmap@firs.gov.ng
for all MAP cases, please copy requests to: Head, Treaties & International Tax Policy Division, FIRS, 2nd Floor, Revenue House Annex, 26 Sokode Crescent, Wuse Zone 5, Abuja, FCT, Nigeria. Phone No: +2348025018750; +2348035512420; Email Address: kajesomo.kehinde@firs.gov.ng
for specific MAP cases involving transfer pricing, the request should also be copied to: Head, International Tax Department 3rd Floor, FIRS Building 17B, Awolowo Road, Ikoyi, Lagos, Phone Nos: +2349070319922; +2348033093287; Email Address: ab.aliyu@firs.gov.ng.
Figure 1. Competent Authority Organisational Structure
Source: OECD
Table 2. Guidance on the MAP process
Overview of Nigeria's MAP Statistics for 2022
Please refer to https://www.oecd.org/tax/dispute/map-statistics-nigeria.pdf for details with respect to Nigeria's MAP Statistics.
Figure 2. Cases closed in 2022
Source: OECD
Figure 3. Evolution of Nigeria's MAP caseload (2016-22)
Source: OECD
Table 3. Overview of Nigeria’s MAP caseload for 2022
Source: OECD
Table 4. Nigeria’s average time to resolve MAP cases in 2022
Source: OECD