Transfer Pricing (TP) is often associated with contentious disputes. This is understandable, as tax audits frequently involve the uncertainty surrounding what constitutes a “fair price,” especially in the absence of comparable transactions, issues of double taxation, and inconsistencies in applying the arm’s length principle. To provide clarity and foster collaboration between Multinational Enterprises (MNEs) and tax authorities, the Federal Inland Revenue Service (FIRS) issued the Guidelines on Advance Pricing Agreements (the “Guidelines”) on 27th November 2024.