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

Regulation 1
(1) These Regulations apply to
(a) a transaction between persons who are in a controlled relationship;
(b) dealings between a permanent establishment and its head office;
(c) dealings between a permanent establishment and other related branches of that permanent establishment;
(d) a transaction between a taxpayer and another taxpayer who are in a controlled relationship; and
(e) a transaction between a taxpayer and another taxpayer who are in an employment relationship.

(2) For purposes of regulations 1(a), (d) and (e), transaction includes
(a) the purchase and sale of goods;
(b) the purchase, sale, lease or use of a tangible asset;
(c) the purchase, sale, lease or use of an intangible asset;
(d) the provision of management services, technical services and other intra group services;
(e) the provision of finance and other financial arrangements;
(f) rent and hire charges; and
(g) any other transaction that may affect the profit or loss of the entity.

(3) For purposes of regulation 1(b) and (c), a permanent establishment is deemed to be a separate legal entity.

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