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Ghana's transfer pricing laws combat "inadequate" taxation

The Ghanaian Parliament has adopted transfer pricing regulations to combat the "inadequate" taxation of transactions between related enterprises.


The Committee of Subsidiary Legislation filed a report to Parliament to implement a transfer pricing framework in Ghana.

Felix Abayateye, vice chairman of the committee, said the absence of transfer pricing regulations in Ghana was leading to “inadequate” taxation of multinational companies.

Companies included in the reference to inadequate taxation include SAB Miller, a drinks manufacturer, which was accused by an ActionAid report of manipulating its transfer pricing to avoid paying tax in Ghana and other sub-Saharan African countries.

This led to informal investigations by five different tax authorities.

Taxpayers in Ghana can choose from comparable uncontrolled price, the resale price, the cost plus, the profit and the transactional net margin methods.

Other methods are available on application to the revenue authority.

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