Transfer Pricing (TP) Rules, Procedures and Documentation: A perspective on Ghana

Abstract

This working paper examines the effectiveness of Ghana’s legal and institutional framework for transfer pricing, a key issue in curbing illicit financial flows (IFFs) from resource-rich developing countries. Focusing on the country’s alignment with OECD guidelines, the study explores the limitations of the Ghana Revenue Authority’s (GRA) capacity, regulatory discretion, and documentation standards. It highlights challenges such as weak institutional infrastructure, absence of reliable comparables, and the risk of abuse in discretionary audits. The authors call for legislative updates and pragmatic administrative reforms—including safe harbours, simplified valuation methods, and stronger capacity-building for tax officials—to enhance domestic revenue mobilization in support of the SDGs.

Keywords: Transfer Pricing, Illicit Financial Flows (IFFs), Tax Policy, Natural Resource Governance, Ghana, Multinational Enterprises (MNEs), MNEs, Tax Avoidance, Revenue Mobilization, Sustainable Development Goals (SDGs), SDGs