The Federal Inland Revenue Authority (FIRS) issued a public notice on 4 January 2022 announcing that it will resume the CbC report local filing requirement for non-parent entities.
In May 2021, FIRS had issued a notice to suspend CbC filing for Nigerian resident branches and subsidiaries (constituent entities) of foreign multinational enterprises.
The withdrawal of the May 2021 suspension follows a review of Nigeria’s compliance with the confidentiality and data safeguard requirements to qualify as a reciprocal jurisdiction for CbC reporting purposes.
The local filing requirement applies or re-applies from 1 January 2021.
Constituent entities of foreign companies will be require to submit a CbC report to the FIRS when there is no agreement for an automatic exchange of information between Nigeria and the country of resident of the ultimate parent entity.