Multinational Enterprises and their subsidiaries can now file their Country-by-Country (CbC) Reports
According to the public notice, this withdrawal is consequent upon the review of Nigeria under the confidentiality and data safeguard, as well as the subsequent submission of Nigeria’s notification for reciprocal exchange of the CbC Reports.
Recall that on May 6, 2021, the FIRS issued a public notice to suspend branches and subsidiaries of MNEs operating in Nigeria to submit their CbC Reports to the FIRS, where no Automatic Exchange of Information exists between Nigeria and the Ultimate Parent Entity (UPE)’s country of residence.
Highlights of the Public Notice
With the announced withdrawal of the suspension, affected MNEs are now obligated to submit their CbC Reports to the FIRS with effect from 1st January 2022.
Nigerian constituent entities are still required to file their annual CbCR Notification which provides information on the identity and tax residence of the entity preparing the CbC Reports on behalf of the MNE group before the end of its financial reporting year.
Key takeaway
Nigerian branches and subsidiaries of MNEs are advised to check with their UPE whether an Automatic Exchange of Information exists with their jurisdiction. The outcome of this would determine if a CbC Report would be submitted in Nigeria or not.
Should you require assistance with fulfilling this obligation, do not hesitate to contact us at Mazars Nigeria.
Contacts
Peter Nwofia,
Partner, Tax and Regulatory Services, Mazars
Olufunso Ola-Ojo,
Director, Tax and Regulatory Services, Mazars
Olufunso.Ola-Ojo@mazars.com.ng
Oluwatobi Olafaju,
Manager, Tax and Regulatory Services, Mazars
Oluwatobi.Olafaju@mazars.com.ng