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Transfer Pricing Regulations, 2012 (L.I. 2188)

Regulation 7 (2) & (3)
(2)  That person shall for purpose of these Regulations file returns on income in accordance with section 72 of the Act.

(3) The form prescribed by the Commissioner-General for purposes of filing returns on income shall include a requirement to provide information 
(a) on the transfer pricing method selected by the person, including information on
(i) any adjustment made as a result of applying that method;
(ii) any assumption made in applying that method;
(iii) the justification for the use of that method;
(iv) the comparables chosen and the screening criteria for choosing the comparables; and
(v) the comparability analysis of the associated party transactions and the comparables;
(b) on the calculations made and price adjustment factors considered necessary for purposes of achieving the comparability;
(c) on any arm's length range determined by the person who is under examination and any reasons in support of that determination and the use of that range;
(d) on the organisational structure of the person globally, showing the location and ownership linkages amongst associated persons;
(e) describing the nature of the business in which the relevant transaction took place, the property used and the extent of any other commercial or financial relationship;
(f) that provide details of transactions between a person and other associated persons, including
(i) any contracts or agreements that specifies the terms of the transactions; and
(ii) segmented financial accounts with respect to the transactions and explanations on the assumptions made to derive the segmented information;
(g) on strategies and policies applied and information analysis relied on by the person to determine and ensure that the transaction is at an arm's length;
(h) on the identity of that person and the relation between that person and other persons in the controlled relationship;
(i) kept as a record of transactions between that person and other persons;
(j) that provides the details of 
(i) the principal business activities of each person in the group; and
(ii) the business relationships amongst the associated persons, including services provided, goods sold, intangible use;
(k) on the consolidated financial statement of the group;
(l) on each associated party, including
(i) information on the line of business of the associated person, industry dynamics; market, regulatory and economic conditions in which the associated person operates;
(ii) information on the functions and risks of the associated person, and assets employed by the associated person; and
(iii) financial statements; and
(m) that the Commissioner-General considers relevant.Regulation 7





Subject : TRANSFER PRICING  

Procedure to Follow


Not Avaiable

Responsible Institution


Ghana Revenue Authority

Location: Off Starlets 91 Road, near Accra Sports Stadium

Relevant Forms to Download

Not Available

Online System
Fees/ charges

Not Avaiable