Title: Ghana's current transfer pricing regime: exposition and critique

Authors: Abdallah Ali-Nakyea; William Kofi Owusu Demitia

Addresses: University of Ghana School of Law, P.O. Box LG 70, Legon-Accra, Ghana; Ali-Nakyea and Associates PRUC, P.O. Box YK 66, Kanda-Accra, Ghana ' University of Ghana School of Law, P.O. Box LG 70, Legon-Accra, Ghana; Arete Solicitors PRUC, No. F89/7 Emmaus Road, Off 2nd Labone Street, Labone-Accra, Ghana

Abstract: The Transfer Pricing Regulations, 2020 (L.I. 2412) can be described as Ghana's attempt to address the contemporary challenges associated with transfer pricing abuse by taxpayers and the effects of those abuses on revenue generation and the development of the nation. This article compares Ghana's old Transfer Pricing Regulations, 2012 (L.I. 2188) to current Transfer Pricing Regulations, 2020 (L.I. 2412) and discusses the significant improvements that L.I. 2412 has made to the transfer pricing regulatory framework in Ghana. The article also highlights the shortcomings of the current regulations and offers some proposals to further strengthen the regulations to address contemporary developments within the transfer pricing landscape in Ghana.

Keywords: abuse; contemporary; challenges; critique; development; exposition; revenue; improvements; transfer; pricing.

DOI: 10.1504/IJPLAP.2025.145286

International Journal of Public Law and Policy, 2025 Vol.11 No.2, pp.161 - 191

Received: 05 Sep 2023
Accepted: 10 Oct 2023
Published online: 31 Mar 2025 *

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