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.
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

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