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 2025

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

Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards
The fates of pillars one and two hang in the balance after the US successfully threw its weight around in G7 and Canadian negotiations
Rafael Tena tells ITR about the ‘crazy’ Mexican market, ditching the hourly rate, and refusing to grow his fledgling firm in an ‘unstructured way’
It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data
The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure
New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer
The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR
Indirect tax professionals now rate compliance as a bigger obstacle than technology and automation; in other news, Italy approved a VAT cut on art sales
AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems
FTI Consulting’s EMEA head of employment tax and reward tells ITR about celebrating diversity in the profession, his love of musicals, and what makes tax cool
Gift this article