In this second part of our overview of current transfer pricing
regulations on the African continent, we focus on relevant
provisions in, amongst others, Ghana, Nigeria and Uganda.
The Ghanaian Transfer Pricing Regulations, 2012 (L.I.2188) (the
Ghanaian Regulations) were introduced by the Ghana Revenue
Authority (GRA) on 27 July 2012, effective from 14 September 2012,
to provide practical guidance regarding the implementation of the
general anti-avoidance provisions contained in the Internal Revenue
Act (IRA). In terms of the Practice Notes on transfer pricing,
released in January 2013, the GRA will apply the principles
contained in the OECD Transfer Pricing Guidelines for Multinational
Enterprises and Tax Administrations (OECD Guidelines), except when
they are inconsistent with the provisions of the Ghanaian
Regulations.
