No form of combined reporting of results of operations by a group or affiliates is permitted.
The Transfer Pricing Regulations follow the internationally accepted guidelines published by the Organisation for Economic Co-operation and Development (OECD), only with a much broader perspective on the nature of entities and transactions.
The Regulations cover transactions between persons in a controlled relationship (related parties, including PEs and employees). It prescribes the transfer pricing methods and documentation that entities are required to maintain and retain.
The Regulations also require entities with related-party transactions to file a return, supporting documentation and country-by-country report on an annual basis.
Interest expenses and foreign exchange currency losses incurred on related-party debt by an entity (other than a financial institution) in which 50% or more of the underlying ownership or control is held by an exempt person, either alone or together with an associate, are not allowed as a deduction in arriving at the chargeable income of the entity if the entity is thinly capitalised. An entity controlled by an exempt person is deemed to be thinly capitalised if its debt-to-equity ratio exceeds the ratio 3:1.
Thin capitalisation provisions do not apply to resident financial institutions.
Controlled foreign companies (CFCs)
There are no provisions for CFCs in the tax laws of Ghana.