Understand the principles of international taxation and the interaction of Ghana's tax system with other jurisdictions — transfer pricing, tax treaties, and cross-border planning.
International Taxation is one of the most sought-after areas of tax expertise in Ghana, driven by the growth of multinational businesses and cross-border investment. This paper covers the foundational principles of international tax — residency, source jurisdiction, permanent establishments, and double taxation — as well as practical transfer pricing methodologies, the OECD and UN Model Conventions, thin capitalisation rules, and the ethics of international tax planning. Candidates who excel in this paper are equipped for careers in Big 4 international tax teams, multinational corporations, and the Ghana Revenue Authority's transfer pricing unit.
Residence vs. source systems; definition of residence for individuals and companies; dual residency; tax havens.
Definition of PE; attribution of profits to PE; branch vs. subsidiary; departures and exit tax mechanisms.
Connected persons; transfer pricing adjustments; comparability analysis; the arm's length range.
CUP, Resale Price, Cost Plus, Profit Split, TNMM — when to apply each and how to document compliance.
Establishing arm's length royalties; valuation of intangibles; OECD guidance; cost contribution arrangements.
Judicial and economic double taxation; exemption and credit systems; the mechanics of the foreign tax credit.
OECD Model and UN Model conventions; key articles (residence, dividends, interest, royalties, PE); treaty shopping and anti-abuse.
Arm's length approach to related-party debt; safe harbour ratios; restriction on back-to-back structures.
Transfer pricing questions always require you to: (1) identify the transaction, (2) select the most appropriate method with justification, (3) apply the method, and (4) identify documentation requirements. Skipping any step costs marks.
International Tax Manager
Transfer Pricing Specialist
GRA Transfer Pricing Officer
OECD/UN Tax Policy Consultant
Multinational Tax Director
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