QUESTIONS AND ANSWER ON REV360
QUESTIONS
1. “Are you part of a Multinational Enterprise (MNE) Group?”
is asking whether your company belongs to a business group that operates in more than one country.
ANSWER
An MNE Group generally means:
- A parent company and its related/subsidiary companies
- Operating in two or more countries
- Under common ownership or control
Examples of an MNE Group
A company may be considered part of an MNE Group if:
- A foreign company owns your Nigerian company
- Your Nigerian company owns or controls businesses outside Nigeria
- Your company and other foreign companies are under the same parent company
For example:
- A Nigerian subsidiary of a UK, US, or Chinese company
- A group with branches or subsidiaries in Nigeria, Ghana, Kenya, and UAE
- International corporate groups with centralized management
When to answer “YES”
Select YES if:
- Your company has foreign parent companies, subsidiaries, affiliates, or branches
- The group operates in multiple countries
- There is common control or ownership internationally
When to answer “NO”
Select NO if:
- Your business operates only in Nigeria
- You are not owned by or connected to foreign entities
- You are a standalone local company without international group structure
Why REV360 asks this
REV360 may request this information for:
- Transfer Pricing compliance
- International tax reporting
- Country-by-Country Reporting (CbCR)
- BEPS compliance requirements
- Related-party transaction monitoring by Nigeria Revenue Service
“IS ANY OF YOUR CONSTITUENT ENTITIES A CFC?”
is asking whether any company within your group structure qualifies as a Controlled Foreign Company (CFC).
A CFC generally means:
- A foreign company (incorporated outside Nigeria)
- That is controlled directly or indirectly by Nigerian shareholders, parent companies, or related entities.
Breaking it down simply
“Constituent entities”
These are the different companies, subsidiaries, branches, or related entities within a group structure.
“Controlled Foreign Company (CFC)”
This refers to a foreign entity that is substantially owned or controlled by a Nigerian company or Nigerian tax residents.
Example of a “YES”
Suppose:
- A Nigerian parent company owns:
- 80% of a company in Ghana
- 60% of a company in the UK
Those foreign subsidiaries may be regarded as CFCs.
In that case, the answer could be YES.
Example of a “NO”
If:
- The business only operates in Nigeria
- Has no foreign subsidiaries or foreign-controlled entities
- Or is not part of an international group structure
Then the answer is usually NO.
Why REV360 is asking this
REV360 is collecting information for:
- International tax compliance
- Transfer pricing monitoring
- BEPS reporting
- Multinational enterprise disclosures
- Cross-border taxation assessment
This is commonly relevant for:
- Multinational groups
- Companies with foreign subsidiaries
- Cross-border ownership structures
- International investments
For many small and medium Nigerian businesses with only local operations, the answer is often NO.
