Section 192

(1) A company involved in an arrangement with a related party Transactions
shall – between
related
(a) ensure that the terms and conditions for which the arrangement is parties to be
carried out is at arm's length; and at arm's
length
(b) report the arrangement in the form and manner prescribed by the
relevant tax authority.
(2) Where, in the opinion of a relevant tax authority, a company has
entered into an arrangement with a related party which is not at arm's length,
it may effect necessary adjustments to bring the arrangement in conformity to
arm's length terms as provided under the Transfer Pricing Regulations.
(3) The relevant tax authority may make rules or regulations for the
administration of this section.
(4) For the purposes of this section –
(a) an "arrangement" includes any agreement, understanding, scheme,
financial or commercial relation, transaction or series of transactions; and
(b) "arm's length terms and conditions" means such terms and condi-
tions obtainable if the transaction or arrangement was between unrelated
parties dealing in comparative circumstances.
A 498 2025 No. 7 Nigeria Tax Act, 2025