Transfer Pricing Regulations, 2012 (L.I. 2188)
Regulation 5 (1) - (3)
(1) The Commissioner-General shall consider a service charge between persons in a controlled relationship to be consistent with the arm's length principle, if
(a) the charge is for a service that is actually rendered,
(b) the service provides economic or commercial value to the recipient of the service, and
(c) an independent person in a comparable circumstance will pay that charge for the service.
(2) A charge for a service paid by a person to another person who is in a controlled relationship with that person is not consistent with the arm's length principle, if it is paid by that person
(a) for a service specified in sub regulation (3), and
(b) because of the ownership interest of the shareholder of the person in one or more of the companies in the group.
(3) The service referred to in sub regulation (2) (a); includes
(a) a service rendered in relation to the juridical structure of the parent company of the person, for example meetings of shareholders of the parent company, issuing of shares in the parent company and costs of the supervisory board of the parent company;
(b) a service rendered in relation to reporting requirements of the parent company of the person, including the consolidation of reports; and
(c) a service rendered in relation to the raising of funds for the acquisition of participation, except where the participation is directly or indirectly acquired by the person and the acquisition benefits the person or is expected to benefit the person.
Procedure to Follow
Not Avaiable
Responsible Institution
Location: Off Starlets 91 Road, near Accra Sports Stadium
- Email: info@gra.gov.gh
- Website: www.gra.gov.gh/
- GPS: GA-144-3422
- Telephone: 0800900105
Relevant Forms to Download
Not Available
Online System
Fees/ charges
Not Avaiable
Loading. Please wait....