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Africa update: Ghana and Cameroon tighten transfer pricing

African nations are strengthening their tax systems and transfer pricing has become a new focus in the region.

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Ghana is the most recent country to implement transfer pricing legislation, with assistance from the German development agency, GIZ. The rules are expected to be in place by the end of this month.

Ghana was subject to alleged transfer pricing abuse last year in the reported operations of drinks company SAB Miller, by ActionAid and the rules are an attempt to level the playing field in the country, extracting more revenue from multinational enterprises (MNE) working in the country.

Additionally, Cameroon updated its transfer pricing regulations in its 2012 Finance Law stating an automating obligation to produce documentation at the beginning of a tax audit for companies registered in the large taxpayer unit and only on request from the authorities for all other taxpayers.

On taxpayers registered in the large taxpayer unit, the obligation only applies if the company has 25% of its capital or voting rights held directly or indirectly by an entity outside Cameroon holds 25% of capital or voting rights of an entity outside Cameroon.

The time limit for tax audits has been extended from three to six months for transfer pricing issues and there is a greater focus on intangible assets, cost allocation, cost sharing and financial transactions.

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