Loading
Initializing StudyMate
One of the most commercially critical areas of international tax. Master the OECD Guidelines, UN Manual, and navigate Ghana's L.I. 2412 compliance landscape.
Transfer Pricing (TP) governs how transactions between related companies in different countries are priced for tax purposes.
This module covers the OECD Transfer Pricing Guidelines, the UN Practical Manual on Transfer Pricing, and the post-BEPS framework. It is an optional module and can also be taken standalone for a TP certificate.
Ghana's Transfer Pricing Regulations are directly grounded in OECD principles. Understanding ADIT Module 3.03 gives practitioners a deep technical foundation for advising Ghanaian and pan-African multinationals on TP compliance, documentation, and dispute resolution.
| 1 | The Arm's Length Principle — Article 9 OECD/UN Models |
| 2 | Functional Analysis — functions, assets, risks |
| 3 | Comparability Analysis — finding comparables |
| 4 | TP Methods — CUP, Cost Plus, Resale Price, TNMM, Profit Split |
| 5 | Selection and Application of TP Methods |
| 6 | Special Transactions — intangibles, financial transactions, services |
| 7 | Intangible Assets — DEMPE functions |
| 8 | Financial Transactions — intercompany loans, guarantees, treasury |
| 9 | Intra-group Services — low value-adding services |
| 10 | Permanent Establishments and TP |
| 11 | BEPS Actions 8–10 — aligning TP outcomes with value creation |
| 12 | BEPS Action 13 — CbCR, Master File, Local File |
| 13 | Advanced Pricing Agreements (APAs) |
| 14 | TP Compliance and Documentation requirements |
| 15 | Dispute Resolution — MAP, arbitration, domestic remedies |
| 16 | UN Manual — TP approaches for developing countries |
| 17 | Recent Developments — OECD Pillar One (Amount B) |
Prof. Bill Cobby Impriam
"Bill is a practicing tax advisor with deep experience in Ghana's TP compliance landscape. He teaches Transfer Pricing from the examiner's framework AND from real advisory experience."