For Nigerian tax purposes recharges can be defined as costs reimbursed by a non-resident company to its Nigerian affiliate in respect of services provided by the affiliate in execution of a joint contract in Nigeria. Generally, this amount includes a profit mark-up for the affiliate, and the non-resident company is allowed the amount as a deduction in its income tax returns.
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While it’s great that the OECD is alive to multinationals’ fears of being caught in a compliance trap, the ‘common understanding’ illustrates a worrying lack of readiness
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