Critical Analysis: Transition from E-TP Plat to TaxPro-Max for Transfer Pricing Returns and CbCR Notifications

The Federal Inland Revenue Service (FIRS) has issued a public notice announcing the migration of the annual filing of Transfer Pricing (TP) returns and Country-By-Country Reporting (CbCR) Notifications from E-TP Plat to the Taxpro-Max platform. This aims to consolidate both platforms, thereby reducing the compliance burdens for taxpayers. The E-TP Plat was initially introduced in 2020 to facilitate the electronic filing of various returns such as: ‘TP Declaration forms’, ‘TP Disclosure Forms’, ‘CbCR Notification forms’, and ‘CbC reports’, which were all previously filed manually, while the Taxpro-Max platform was deployed later in 2021 for filing other tax returns such as Companies Income Tax (CIT), Withholding Tax (WHT) and Value Added Tax (VAT) returns. The FIRS notice also announced a waiver of all administrative penalties imposed by the Nigerian Income Tax (Transfer Pricing) Regulations, 2018 {‘TP Regulations’} and Income Tax (Country by Country Reporting) Regulations, 2018 {‘CbCR Regulations’} in relation to all outstanding returns, with the condition that all required filings must be completed via the Taxpro-Max platform not later than 30 June 2024. However, penalties shall be imposed on any taxpayer who fails to comply with the stated conditions for the waiver. Additionally, taxpayers may choose to refile all TP and CbCR returns previously filed on the E-TP Plat on TaxPro-Max.

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