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Cost Contribution Arrangements (“CCAs”)

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Managing conflicts between domestic laws and adopted international tax guidelines and best practices in Nigeria

The last six years have witnessed significant efforts by Nigeria to align its domestic tax laws and regulations with international initiatives on modernization of its tax principles and enhancement of transparency and disclosure requirements. These efforts included the introduction of Income Tax (Transfer Pricing) Regulations No.1 in August 2012 (“TP Regulations”), which adopted international best practices for determining the arm’s length/market value of transactions between related parties. Nigeria has also been participating in global initiatives aimed at tackling tax evasion and tax revenue leakages.

However, these adopted international best practices and rules may, in some instances, be in conflict with Nigeria’s domestic tax laws, principles and administrative practices, thereby limiting or nullifying the desired effects of the adopted international tax principles.

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One of the areas where potential conflicts exist relates to local implementation of the principles and guidelines for determining arm’s length nature of Cost Contribution Arrangements (“CCAs”).

CCAs are defined in the ‘Transfer Pricing Guidelines for Multinationals and Tax Administrators’ as “…contractual arrangements among business enterprises to share the contributions and risks involved in the joint development, production or the obtaining of intangibles, tangible assets or services with the understanding that such intangibles, tangible assets or services are expected to create benefits for the individual businesses of each of the participants.” [Organization for Economic Cooperation and Development, July 2017, Pg. 345] (“OECD TP Guidelines”). CCAs are classified into either Development (for the joint development, production or the obtaining of intangibles or tangible assets), or Service (for the joint procurement of services) CCAs.

While CCAs represent sharing of resources to achieve a common goal, each participant’s contribution should still be at arm’s length – consistent with the benefits they expect to derive from the arrangement. Hence, to aid in verifying arm’s length terms, OECD TP Guidelines recommend inclusion of certain information in any CCA, such as list of the participants, the nature and extent of each participant’s expected benefit from the underlying activities, the cost allocation/ contribution mechanism, arrangements for monitoring the operations of the CCA, etc

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Coronavirus

Covid-19 Update in Nigeria

On the 24th of May 2020, 313 new confirmed cases and 5 deaths were recorded in Nigeria bringing the total confirmed cases recorded in the country to 7,839.

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COVID-19: FCMB reschedule operations

The spread of novel Corona Virus Disease (COVID-19) in Nigeria has continued to rise rapidly as the latest statistics provided by the Nigeria Centre for Disease Control revealed Nigeria now has 7,839 confirmed cases.

On the 24th of May 2020, 313 new confirmed cases and 5 deaths were recorded in Nigeria.

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To date, 7839 cases have been confirmed, 2263 cases have been discharged and 226 deaths have been recorded in 34 states and the Federal Capital Territory having carried out 44,458 tests.

The 313 new cases were reported from 17 states- Lagos (148), FCT (36), Rivers (27), Edo (19), Kano (13), Ogun (12), Ebonyi (11), Nasarawa (8), Delta (8), Oyo (7), Plateau (6), Kaduna (5), Kwara (4), Akwa Ibom (3), Bayelsa (3), Niger (2), Anambra (1).

READ ALSO: COVID-19: Western diplomats warn of disease explosion, poor handling by government

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In a move to combat the spread of the pandemic disease, President Muhammadu Buhari directed the cessation of all movements in Lagos and the FCT for an initial period of 14 days, which took effect from 11 pm on Monday, 30th March 2020.

The movement restriction, which was extended by another two-weeks period, has been partially put on hold with some businesses commencing operations from May 4.

The latest numbers bring Lagos state total confirmed cases to 3505, followed by Kano (896), Abuja at 505, Katsina (308), Borno (250), Jigawa (241), Oyo (240), Bauchi (232), Ogun (231), Edo (191), Kaduna (189),  Gombe (145),  Sokoto and Rivers (116), Plateau (83).

Kwara State has recorded 79 cases, Yobe (47), Nasarawa (46), Osun (42), Delta (39), Ebonyi (33), Kebbi (32), Niger (28), Adamawa (27), Akwa Ibom (24), Ondo (23), Ekiti (20), Taraba and Enugu (18), Bayelsa (11), Anambra (9), Imo and Abia (7), while Benue state has recorded 5 cases.

READ ALSO: Bill Gates says Trump’s WHO funding suspension is dangerous

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DateConfirmed caseNew casesTotal deathsNew deathsTotal recoveryActive casesCritical cases
May 24, 202078393132265226353607
May 23, 202075262652210217451317
May 22, 2020726124522110200750337
May 21, 2020701633921111190748987
May 20, 202066772842008184046377
May 19, 202064012261921173444757
May 18, 202061752161919164443407
May 17, 202059593881826159441837
May 16, 202056211761765147239737
May 15, 202054452881713132039544
May 14, 202051621931683118038154
May 13, 202049711841646107037374
May 12, 20204787146158695936704
May 11, 202046412421521090235894
May 10, 202043992481421777834794
May 9, 202041512391271174532784
May 8, 202039123861181067931154
May 7, 20203526381108460128184
May 6, 20203145195104553425071
May 5, 2020295014899548123704
May 4, 2020280224594641722912
May 3, 2020255817088240020702
May 2, 20202388220861735119522
May 1, 20202170238691035117512
April 30, 2020193220459731715562
April 29, 2020172819652730713692
April 28, 2020153219545425512322
April 27, 20201337644102559942
April 26, 20201273914152399942
April 25, 20201182873632229252
April 24, 202010951143312088552
April 23, 20209811083231977532
April 22, 2020873912931976482
April 21, 20207821172631975602
April 20, 2020665382311884662
April 19, 2020627862221704362
April 18, 2020541482021663562
April 17, 2020493511841593172
April 16, 2020442351311522772
April 15, 2020407341211282672
April 14, 202037330111992632
April 13, 202034320100912422
April 12, 20203235100852282
April 11, 202031813103702382
April 10, 20203051770582402
April 9, 20202881471512302
April 8, 20202742260442262
April 7, 20202541661442042
April 6, 2020238650351982
April 5, 20202321851331942
April 4, 2020214540251850
April 3, 20202092542251800
April 2, 20201841020201620
April 1, 2020174352091630
March 31, 202013982091280
March 30, 2020131202181210
March 29, 2020111221031070
March 28, 20208919103850
March 27, 2020705103660
March 26, 20206514102620
March 25, 2020517102480
March 24, 2020444102410
March 23, 20204010112370
March 22, 2020308002280
March 21, 20202210001210
March 20, 2020124001110
March 19, 20208000170
March 18, 20208500170
March 17, 20203100030
March 16, 20202000020
March 15, 20202000020
March 14, 20202000020
March 13, 20202000020
March 12, 20202000020
March 11, 20202000020
March 10, 20202000020
March 9, 20202100020
March 8, 20201000010
March 7, 20201000010
March 6, 20201000010
March 5, 20201000010
March 4, 20201000010
March 3, 20201000010
March 2, 20201000010
March 1, 20201000010
February 29, 20201000010
February 28, 20201100010

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Coronavirus

British High Commission releases flight schedule for final evacuation

The commission also made provisions for nationals who are cash strapped.

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The British High Commission has released flight schedules to evacuate its nationals from Nigeria within a fortnight.

In a video made available to Nairametrics, the British High Commissioner to Nigeria, Catriona Laing, stressed that they would be the final evacuation flights from Nigeria back to the United Kingdom, and urged nationals to take advantage of it.

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Speaking about eligibility, Laing stated:

“These flights are aimed at British nationals and dual nationals who are normally resident in the UK, and their immediate dependents. We’ll be prioritising people who are already on our waiting list.
“After that, we will allocate seats on a first come first served basis, and those of you who are non-British nationals but have indefinite leave to remain in the UK could also be eligible. We will pick up any foreign nationals if we have seats available.”

READ ALSO: British airways set to suspend 32,000 employees

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Schedule

There will be flights from Lagos to London on May 29, and June 1, 2020, while the flights from Abuja to London will only run on June 6, 2020.
There are also arrangements to pick up stranded nationals in Port Harcourt, and connect them to Abuja where they will board the flight home.

According to Laing, the Commission will be using Virgin Airlines for its Lagos flights and Titan Airways to convey nationals from Abuja.

READ ALSO: Time for Nigeria to forget crude oil

What it will cost

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Britons taking the flight from Lagos will be expected to pay £445 for their tickets, while passengers from Abuja will pay £600.

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Laing added that the commission has also made provisions for nationals who are cash strapped.
“If you are struggling and you have exhausted all other means, there are loans available,” she said.

Bookings are to be made at the ‘return to the UK’ part of their travel advise page, and details of the loans can also be found there.

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Economy & Politics

Lagos to shut down Marine Beach bridge for emergency repairs

The closure will allow the Federal Ministry of Works to carry out emergency repairs on the bridge, in line with the government’s vision of providing a better transportation system in the state.

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Lagos to shut down Marine Beach bridge for emergency repairs

Lagos state government has announced that the Apapa Marine Beach bridge will be closed for five months, from Wednesday 27th May, to Wednesday 21st October, 2020.

The closure will allow the Federal Ministry of Works to carry out emergency repairs on the bridge, in line with the government’s vision of providing a better transportation system in the state.

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In a statement from the Lagos state Ministry of Transportation, the Commissioner, Dr. Frederic Oladeinde, noted that the repairs were long overdue, and necessary to ensure safety of Lagosians, given the number of motorists that use the route.

READ MORE: Nigerians knock Fashola over comments on “bad roads”  

The Commissioner noted that the repairs included bearing and expansion joint replacement and would be executed in two phases, taking one lane of the bridge at a time.

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The first phase will involve handling the lane inbound Apapa while the second phase will be designated to work on the lane that conveys vehicles outside the axis,” he said.

Alternative routes

Oladeinde noted that alternative routes around the bridge had been improved to make them motorable, and ease movements for road users.

READ ALSO: Osinbajo sets up committee on reopening of Nigerian economy, suspends loan deductions for states

To manage the construction period, the statement noted that Traffic Management Authorities would be hard at work to ameliorate the expected traffic issues and supervise other arrangements.

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“Motorists inwards Wharf road will be diverted to the other section of the bridge outwards Apapa, a contraflow of 200metres has been put in place for vehicles to realign with a proper direction inwards Ajegunle or Wharf road, Apapa, while Motorists descending to Total Gas under bridge will drive without any hindrance,” it read.

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The Commissioner called for the understanding and cooperation of motorists and road users during the period to ensure a smooth flow of plans.

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