Africa update: Ghana and Cameroon tighten transfer pricing

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


Africa update: Ghana and Cameroon tighten transfer pricing

African nations are strengthening their tax systems and transfer pricing has become a new focus in the region.

africa150.jpg

Ghana is the most recent country to implement transfer pricing legislation, with assistance from the German development agency, GIZ. The rules are expected to be in place by the end of this month.

Ghana was subject to alleged transfer pricing abuse last year in the reported operations of drinks company SAB Miller, by ActionAid and the rules are an attempt to level the playing field in the country, extracting more revenue from multinational enterprises (MNE) working in the country.

Additionally, Cameroon updated its transfer pricing regulations in its 2012 Finance Law stating an automating obligation to produce documentation at the beginning of a tax audit for companies registered in the large taxpayer unit and only on request from the authorities for all other taxpayers.

On taxpayers registered in the large taxpayer unit, the obligation only applies if the company has 25% of its capital or voting rights held directly or indirectly by an entity outside Cameroon holds 25% of capital or voting rights of an entity outside Cameroon.

The time limit for tax audits has been extended from three to six months for transfer pricing issues and there is a greater focus on intangible assets, cost allocation, cost sharing and financial transactions.

more across site & shared bottom lb ros

More from across our site

It was also a memorable night for Galicia, KPMG, Skadden and Pinheiro Neto, all of which scooped major awards at a gala ceremony in New York
The former Deloitte UK CEO earned a 45% raise in a year when 1,000 staff reportedly lost their jobs – and the pay gap is only getting bigger
In a seminal development for big law, the 95-year-old firm is set to cease operations after a series of high-profile partner departures
UK Chancellor John Healey extended a VAT cut, suspended tariffs, increased a bank surcharge and vowed to increase funding for HMRC
Kristine Riisberg warned that TP decisions can determine top-up tax exposure under pillar two, while global consensus over the rules remains unsettled
Both Germany’s NIS2 and the EU AI Act now determine whether a tax function can meet its obligations – and both can make management personally accountable
Originators, loan purchasers and securitisation vehicles may need to revisit servicing agreements and pricing after a key judgment narrowed the VAT credit management exemption
Opening doors for existing talent within Baker McKenzie and a desire for enhanced legal capabilities informed Ricardo Perera’s switch from KPMG
Boaz Goren’s move to the upstart PE-backed firm takes the number of senior UK tax professionals who have left EY this year to 13
The allegations against Deloitte Cyprus raise uncomfortable questions about how far the big four can distance themselves from misconduct at member firms
Gift this article