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Navigate the Ghana Revenue Authority (GRA) requirements with ease. Stay compliant with L.I. 2419 and ensure your intercompany dealings withstand rigorous scrutiny.
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Transfer pricing in Ghana is primarily governed by the Transfer Pricing Regulations, 2020 (L.I. 2419). The GRA requires taxpayers to maintain contemporaneous documentation and file annual returns disclosing all related-party transactions.
The 2026 enforcement cycle sees a heightened focus on Safe Harbour eligibility, intra-group service charges, and the alignment of local documentation with Global Master File standards to prevent base erosion.
The definitive regulation mandating the Arms Length Principle for all cross-border and domestic controlled transactions.
Mandatory filing within 4 months of the financial year-end. Failure to file triggers automatic GRA risk flags.
New 2025-2026 guidelines targeting intercompany digital service fees and software licensing within Ghana.
The trigger for mandatory contemporaneous documentation.
Contemporaneous documentation is required if the aggregate value of controlled transactions exceeds GHS 200,000 per annum.
Even below this threshold, taxpayers must be able to prove arm's length pricing if requested by the Commissioner-General.
The deadline for the Annual Transfer Pricing Return.
Taxpayers must submit their TP Return through the GRA portal within 4 months after the end of the basis period.
The Master File and Local File do not need to be filed but must be contemporaneous (ready by the return date).
Global transparency for Large Taxpayer units.
MNE groups headquartered in Ghana with consolidated revenue exceeding EUR 750M (or GHS equivalent) must file a Country-by-Country Report.
Local subsidiaries of foreign MNEs must file a CbCR Notification to inform the GRA of the reporting entity.
Accurate preparation and portal lodgment of the Annual TP Return.
Drafting robust documentation that meets L.I. 2419 standards.
Technical support during GRA Transfer Pricing audits and queries.
Applying for simplified compliance for low-value-adding intra-group services.
The GRA is increasing technical audits in the mining, oil, and telecom sectors. Is your documentation contemporaneous?
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