Ghana's transfer pricing laws combat "inadequate" taxation

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

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.

ghana150.png

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.

more across site & shared bottom lb ros

More from across our site

The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR
The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs
In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted
The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed
Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
The global minimum tax deal is not viable without US participation, Friedrich Merz has argued
Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations
Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut
The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year
Gift this article