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

Regulation 2 (3) 
The Commissioner-General shall, in selecting a comparable transaction, consider
(a) whether there exists economically relevant characteristics of the transactions to be compared, in relation to
(i) the characteristics of the goods, property or services transferred;
(ii) the relative importance of functions performed;
(iii) the contractual terms and conditions of the transactions;
(iv) the assets used;
(v) the relative risk assumed by the associated persons and any independent party, where the independent party is considered as a possible comparable;
(vi) the economic and market circumstances in which the transaction takes place;
(vii) the business strategies pursued by the connected persons in relation to the transactions; and
(b) whether significant difference do not exist between the transactions being compared that can materially affect the financial indicator being examined and if a difference exists, what reasonable comparability adjustment can be made to the uncontrolled transaction to eliminate the effect of the difference on the comparison.


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