As the interconnected global economy rapidly evolves against a backdrop of stringent regulatory requirements, emerging technologies and tightening tax budgets, many multinational organizations find themselves navigating increasingly intricate transfer pricing challenges to accommodate ever-shifting business models.
Overview of Transfer Pricing in Ghana
In our ever‑evolving and increasingly interconnected world, Transfer Pricing has become a major focus for tax authorities and multinational businesses. As companies expand across borders and engage in related‑party transactions, the need for robust, transparent, and defensible pricing arrangements has become increasingly critical. Regulatory expectations continue to intensify both locally under Ghana’s Transfer Pricing Regulations, 2020 (L.I. 2412), and globally under OECD guidelines making it essential for organisations to maintain comprehensive documentation, apply appropriate pricing methodologies, and proactively manage intercompany arrangements.
Our Transfer Pricing practice delivers a comprehensive suite of services designed to enhance compliance, manage tax exposure, and align intra‑group agreements and pricing with global best practices.
Our services
Empowering your transfer pricing with precision. Explore how KPMG professionals can support you across the transfer pricing lifecycle, providing a holistic approach to your tax planning.
We support clients with the preparation and timely submission of annual Transfer Pricing returns upon receipt of all required information.
We also review returns prepared internally by clients and handle filing on their behalf to ensure full regulatory compliance.
We assist with the preparation and timely filing of Local Files and Master Files in line with Ghana’s TP Regulations and OECD requirements.
Our team also reviews documentation prepared by clients and manages the filing process to ensure accuracy and completeness.
We review and file Country‑by‑Country (CbC) reports prepared by the group to ensure they comply with Ghana’s Transfer Pricing Regulations and other applicable tax requirements in Ghana.
We perform robust benchmarking studies to determine arm’s-length prices for intercompany transactions, using reliable databases and industry-specific comparables.
We provide end-to end support during transfer pricing audits, from participating in introductory meetings to objection to the decisions of the tax authority where necessary.
Our team also develops a tailored response strategy and prepares detailed submissions to the Ghana Revenue Authority (GRA) to defend your transfer pricing positions.
We assess the taxpayer’s compliance with transfer pricing documentation requirements (including master file, local file and Country-by-Country Reports) and analyse the related party transactions to identify any shortfalls and related tax exposures. We provide actionable recommendations to address the shortfalls and provide support to implement these recommendations.
We support clients in structuring and pricing their intercompany transactions in a way that is both practical and defensible. Our team takes the time to understand how your business operates, then works with you to design transfer pricing models that fit naturally within your commercial reality.
We offer tailored training sessions to help management build practical transfer pricing knowledge and stay current with evolving requirements and emerging developments.
Our insights
Our people
