At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-27. Tax authority: Ghana Revenue Authority (GRA). Summaries are simplified; check the linked official source before relying on them.
The law
#Section 31 of the Income Tax Act, 2015 (Act 896) sets the arm's length standard for arrangements between persons in a controlled relationship (defined in s. 128). The Transfer Pricing Regulations, 2020 (L.I. 2412) were made under s. 31(3) on 7 August 2020, gazetted on 10 August 2020, and replaced the 2012 Regulations (L.I. 2188). Reg. 2 says income and expenses from a controlled arrangement must follow the arm's length standard, meaning terms that do not differ from those of comparable arrangements between independent persons. The Commissioner-General can adjust chargeable income after review (reg. 15) and can recharacterise debt as equity (reg. 15(5), Act 896 s. 31(5)(a)). The GRA's Transfer Pricing Unit sits in the Large Taxpayer Office.
Documentation
#Everyone with a controlled arrangement must keep contemporaneous documentation each year (reg. 12(1)) and file an electronic copy, made of a master file and a local file, with the Commissioner-General within 4 months after the end of the basis period (reg. 12(2) and (3)). A transfer pricing return is due in the same 4 months (reg. 11(1)). Arrangements up to the cedi equivalent of US$200,000 are exempt from the documentation duty (reg. 14(1)). Low value-adding group services at a cost mark-up of 3% or less, and technology transfer charges within 2% of net profit (if registered with the Ghana Investment Promotion Centre), can be exempted by an election filed within 30 days of the arrangement. The election lasts 3 years, and the Commissioner-General replies within 30 days (reg. 14). For extra information the Commissioner-General sets a reasonable time in the request (reg. 11(4)). No fixed response period was found.
Methods
#Reg. 4 and the First Schedule approve the comparable uncontrolled price, resale price, cost plus, transactional net margin and transactional profit split methods. The most appropriate method must be used, judged by strengths and weaknesses, functional analysis, data available and comparability (reg. 5). The Commissioner-General can use or permit another method if none of these works (reg. 4(3) and 5(3)). The arm's length range uses the interquartile range of a three-year weighted average where comparability is uncertain (reg. 17). The Regulations have no advance pricing agreement route.
Penalties
#L.I. 2412 sets no amounts of its own. Reg. 16(2) applies the Revenue Administration Act, 2016 (Act 915) to failures to file, keep documents, underpay or lie. A missing return costs 500 currency points (GHS 500) plus 10 currency points a day (s. 73). Not keeping proper documents costs 75% of the tax for the period if deliberate, otherwise the lesser of that amount and 250 currency points (s. 72). A false or misleading statement costs 100% of the shortfall without reasonable excuse, or 30% in other cases, rising by 20% for each repeat within five years; no penalty applies to an inadvertent error the person discloses voluntarily (s. 74, as amended in 2020). Late tax bears interest at 125% of the statutory rate, compounded monthly (s. 71). Tax from an adjustment is an adjusted assessment (reg. 16(1)). An adviser (EY, May 2024) lists CbC fines of GHS 500 plus GHS 10 a day, and fines of GHS 12,000 to 30,000 or 2 to 5 years in prison for directors.
Pillar Two
#No Pillar Two law was found in Ghana. The 2026 Budget (November 2025) says the Income Tax Act will be reviewed to align with OECD, G20 and ATAF standards, with a draft bill expected with the 2027 Budget. The Income Tax (Amendment) Act 2026 (Act 1178, effective 1 September 2026) changed personal rates and the presumptive tax limit, and the GRA notice shows no minimum tax measure. The domestic 5% of turnover minimum chargeable income (Act 896 s. 2A, added by Act 1094) is not Pillar Two. There are no Ghana filings or deadlines.
Other rules
#Country-by-country reporting applies to groups with consolidated revenue of at least GHS 2.9 billion in the preceding year, and the report and notices are due 12 months after the group's reporting year end (regs. 11(2), 13 and 17). The GRA's CbC form is in Practice Note DT/2021/003 (15 April 2021), which was not opened. Weekend rule: unofficial copies of the Interpretation Act, 2009 (Act 792) s. 44 say a time limit ending on a Saturday, Sunday or public holiday runs to the next day that is none of these, but the official text could not be read, so this tool does not move dates and shows the earlier date. The GRA also sometimes extends a date by notice, as it did for June 2026 returns. The corporate income tax rate is generally 25%. The company return and the TP return are both due 4 months after year end, and a return can be extended by up to 60 days in total on written application made before the due date.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Local file (filed electronically) Contemporaneous documentation must be kept for each year of assessment (reg. 12(1)), and an electronic copy must be filed with the Commissioner-General not later than 4 months after the end of each basis period (reg. 12(2)). The local file content is in reg. 12(5): the Ghana entity, its controlled arrangements, the functional analysis, method, comparables and audited accounts. No extended date is shown: it is not confirmed that a s. 30 extension of the TP return also covers this filing. Not keeping documents costs 75% of the tax for the period if deliberate, otherwise the lesser of that and 250 currency points (Act 915 s. 72). The tool tests the US$200,000 level against total related-party transactions, but the law tests each arrangement. | 4 months after year end (e.g. Apr 30, 2026) | Any person with a controlled arrangement worth more than the cedi equivalent of US$200,000 (reg. 14(1)). The Commissioner-General may add up arrangements built to avoid tax (reg. 14(2)). Low value-adding services at a mark-up of 3% or less and technology transfers within the 2% ranges can be exempted by election (reg. 14). | Transfer Pricing Regulations, 2020 (L.I. 2412) regs. 12 and 14 |
| 2 | Master file (filed electronically) The documentation filed under reg. 12(2) includes both a master file and a local file (reg. 12(3)). The master file covers the group structure, business, intangibles, financing and the group's financial and tax position (reg. 12(4)). It is due within the same 4 months as the TP return. No extended date is shown, because it is not confirmed that a TP return extension covers it. | 4 months after year end (e.g. Apr 30, 2026) | Same persons as the local file. The Regulations set no separate group revenue test for the master file. | Transfer Pricing Regulations, 2020 (L.I. 2412) reg. 12(2) to (4) |
| 3 | Corporate income tax return Due 4 months after the end of the basis period (Income Tax Act s. 124(1)). Provisional tax is paid in four quarterly instalments (31 March, 30 June, 30 September, 31 December of the year of assessment). On written application made before the due date the Commissioner-General may extend the filing date, with all extensions together capped at 60 days; the extension does not move the payment date (Revenue Administration Act s. 30). A late return costs 500 currency points (GHS 500) plus 10 for each day it stays late (s. 73), and late tax carries interest at 125% of the statutory rate, compounded monthly (s. 71). The date is not moved for weekends or holidays (see the weekend rule in Other). | Extended: written application before the due date, up to 60 days in total (Revenue Administration Act s. 30) (e.g. Jun 29, 2026); original due date Apr 30, 2026 | Every company resident in Ghana and every non-resident company with a permanent establishment in Ghana, whether or not tax is due. | Income Tax Act, 2015 (Act 896) s. 124; Revenue Administration Act, 2016 (Act 915) ss. 30, 71 and 73 |
| 4 | Transfer pricing return Due not later than 4 months after the end of each basis period, in the form the Commissioner-General prescribes (reg. 11(1) and (3)). It lists the controlled arrangements, values, method, arm's length range and the consolidated group financial statements. Reg. 16(2) applies the Revenue Administration Act rules on extensions, so the 60-day extension is shown as the extended date. Late filing: 500 currency points plus 10 a day (Act 915 s. 73). Reg. 11(5) applies Act 915 ss. 72 to 74 to a person who ignores an information request. | Extended: written application before the due date, up to 60 days in total (Revenue Administration Act s. 30) (e.g. Jun 29, 2026); original due date Apr 30, 2026 | Every person with an arrangement with a person in a controlled relationship (L.I. 2412 reg. 11(1)). The US$200,000 relief in reg. 14(1) applies to documentation only, not to the return, on the face of the text. | Transfer Pricing Regulations, 2020 (L.I. 2412) regs. 11 and 16 |
| 5 | CbC notification (which entity files the report) Each Ghana-resident constituent entity tells the Commissioner-General no later than 12 months after the last day of the group's reporting year whether it is the ultimate or surrogate parent, or names the reporting entity and its tax residence (reg. 13(5) and (6)). An entity may also tell the GRA that one Ghana entity files for all (reg. 13(3)). | 12 months after year end (e.g. Dec 31, 2026) | A Ghana-resident constituent entity of an MNE group with consolidated revenue of GHS 2.9 billion or more in the year before the reporting year (about EUR 420m when the rules started, below the usual EUR 750m). | Transfer Pricing Regulations, 2020 (L.I. 2412) reg. 13(3), (5), (6) and reg. 17 |
| 6 | Country-by-Country report Filed not later than 12 months after the last day of the group's reporting year, in the template issued by the Commissioner-General (reg. 11(2) and 13(8)). No filing is needed if a surrogate parent files abroad under reg. 13(4). Late filing falls under Act 915 s. 73 (500 currency points plus 10 a day). Reg. 13(1) refers to subregulation (6) for the report content, but the content is in (7). | 12 months after year end (e.g. Dec 31, 2026) | The Ghana-resident ultimate parent of a group with revenue of GHS 2.9 billion or more in the prior year. A Ghana entity of a foreign group files only if the parent is not required to file, its country has no qualifying competent authority agreement with Ghana, or a systemic failure has been notified (reg. 13(2)). | Transfer Pricing Regulations, 2020 (L.I. 2412) regs. 11(2) and 13 |
| 7 | Extra information on request No fixed number of days. The request must state a reasonable time and the information must be sent within it (reg. 11(4)). Non-compliance brings Act 915 ss. 72 to 74 (reg. 11(5)). The only 30-day periods in the Regulations are for election notices and the Commissioner-General's reply to them (reg. 14). | See note | Any person asked in writing by the Commissioner-General. | Transfer Pricing Regulations, 2020 (L.I. 2412) reg. 11(4) and (5) |