Transfer pricing in Ghana

Transfer pricing in Ghana at a glance

Regulation Type OECD
Are there specific transfer pricing regulations? Yes
Submission deadline Contemporaneously
Submission deadline upon request N/A
Annual update required Yes
Official language requirements English
Potential impact of penalties N/A


Ghanaian tax law

Rules for transfer pricing in Ghana are based upon:

  • Transfer pricing regulations 2012 (L.I. 2188)


Ghana is not an OECD member but Ghana’s rules for transfer pricing are in line with the OECD Transfer Pricing Guidelines.


Accepted methods

Accepted methods are:

  • the comparable uncontrolled price method
  • the resale price method
  • the cost plus method
  • the profit split method
  • the transactional net margin method

Priority of methods

Rules for transfer pricing in Ghana state that a taxpayers should use the most appropriate method.

Documentation requirements

Information that should be included in the documentation:

  • The transfer pricing method which includes information on any adjustment made; any assumption made in applying that method; justification for use of the method; the comparables chosen and the criteria for choosing those comparables; the comparability analysis of the associated party transactions
  • The calculations made by the person, with the price adjustment factors considered for purposes of achieving the comparability
  • The arm’s length range determined by the taxpayer and the reasons in support of that determination and use of the range
  • The taxpayer’s global organizational structure, location and ownership linkages amongst associated persons
  • A description of the nature of the business in which the relevant transaction took place, and the property used
  • Details of the intercompany transaction, including: contracts detailing the terms; segmented financial accounts for the transactions and the assumptions made to obtain the segmented information
  • The policies applied and information analysis the taxpayer relied on to determine and ensure that the transaction is at an arm’ s length
  • The person’ s identity and the relation between that person and other persons in the controlled relationship
  • Details regarding the principal business activities of each person in the group; and the business relationship, services provided, goods sold and intangible used in the group’ s consolidated financial statements
  • Information about each associated party; the line of business; industry dynamics; the market, regulatory and economic conditions; the functions, risks, assets used and financial statements


Rules for transfer pricing in Ghana prescribe that all documentation should be submitted in English.

Requirements to prepare documentation annually

In Ghana no specific deadline is in place. However, transfer pricing documentation is expected to be prepared contemporaneously.

Submission deadline upon request by tax authorities

Not applicable.

Advance Pricing Agreements


Rules for transfer pricing in Ghana do not provide for an option to obtain an Advance Pricing Agreement.


Not applicable.


In Ghana no specific transfer pricing penalties are in place, meaning that ordinary tax penalties apply. | the global transfer pricing reference guide