Introduction

The Federal Inland Revenue Service (FIRS) recently announced a significant change regarding the electronic filing of Transfer Pricing (TP) returns and Country-by-Country Reporting (CbCR) notifications. In a public notice, FIRS informed taxpayers about the migration of these filings from the E-TPPLAT platform to the TaxPro-Max (TPM) platform. This move aligns with FIRS’s ongoing efforts to enhance operational efficiency and reduce the compliance burden on taxpayers.

Key Points from the Notice:

• Transition to TaxPro-Max (TPM) Platform:

The annual filing of TP returns and CbCR notifications, previously carried out on FIRS’ E-TPPLAT portal, has now shifted to the TPM platform. Henceforth, taxpayers must file their TP returns and CbCR notifications on TPM using the same login credentials they use for regular tax filings with FIRS.

• Extended Filing Deadline:

FIRS has granted both existing and new taxpayers until June 30, 2024, to complete all pending filing requirements for TP returns and/or CbCR notifications on TPM.

• Penalty Waiver:

Taxpayers complying with the June 30, 2024, deadline will have administrative penalties waived. However, failure to comply will result in penalties as per the Income Tax (Transfer Pricing) Regulations, 2018, and the Income Tax (Country-by-Country) Regulations, 2018.

• Re-filing Option:

Taxpayers can opt to re-file returns previously submitted on E-TPPLAT using the TPM platform. FIRS encourages taxpayers needing clarification to reach out to the Executive Chairman’s office or the Director of FIRS’ International Tax Department for assistance.

Considerations:

The E-TPPLAT portal, launched in March 2020, facilitated electronic filing of annual TP and CbCR returns. The TPM platform, introduced in June 2021, handles Naira-denominated direct and indirect tax returns. Previously, taxpayers had to register on both platforms, leading to duplicate submissions and administrative complexities.

The migration to TPM aims to streamline FIRS’ tax and TP filing processes, benefiting both taxpayers and the Service. However, it’s unclear if FIRS plans to migrate prior filings from E-TPPLAT to TPM for non-compliant taxpayers.

The penalty waiver is a positive step, particularly amid Nigeria’s challenging economic conditions. Taxpayers are urged to seize this opportunity to meet TP and CbCR compliance by the deadline and avoid penalties.

Overall, taxpayers should familiarize themselves with the new filing protocol on TPM to ensure seamless compliance. Those encountering issues during the migration process are advised to seek assistance promptly to meet the deadline. For the full Public Notice, click here.

For professional advice on Accountancy, Transfer Pricing, Tax, Assurance, Outsourcing, online accounting support, Company Registration, and CAC matters, please contact Inner Konsult Ltd at www.innerkonsult.com at Lagos, Ogun state Nigeria offices, www.sunmoladavid.com. You can also reach us via WhatsApp at +2348038460036.