Transfer pricing documentation for a financial services group
Anonymised fintech and payments subsidiary (Lagos, Nigerian operations)
Published March 19, 2026
The Nigerian subsidiary licenses software and brand from a related entity abroad while providing customer support locally. Prior years lacked formal transfer pricing documentation, creating exposure during tax reviews and investor due diligence.
We benchmarked the technology licence and management service fees, documented functional analysis, and prepared a local file aligned to OECD principles as applied in Nigerian practice. Intercompany agreements were updated with pricing clauses, payment terms, and dispute resolution language.
Finance teams were trained on monthly monitoring of related-party balances and withholding tax obligations on outbound payments. The documentation pack supported a clean NRS enquiry and a subsequent equity fundraising data room.
Measurable outcomes
- Local transfer pricing file completed before NRS desk review
- Withholding tax treatment agreed for technology licence payments
- Investor due diligence tax pack delivered within two weeks
- Intercompany balance reconciled monthly with automated alerts