Working Paper 228
This working paper provides an in-depth analysis of Ghana’s evolving role in the international tax landscape. It explores the country’s motivations and experiences in adopting key international tax standards such as exchange of information on request (EOIR), Automatic Exchange of Information (AEOI), transfer pricing rules, and the taxation of digital services. It is part of the International Centre for Tax and Development’s (ICTD) research project – ‘Comparative Perspectives on International Tax from the Global South’ on lower-income countries’ experiences with international tax standards. Ghana initially joined the Global Forum on Transparency and Exchange of Information for Tax Purposes and adopted EOIR reluctantly, but has since demonstrated commitment establishing a dedicated exchange of information (EOI) Unit and becoming one of only six African countries exchanging AEOI data as of April 2025. The Ghana Revenue Authority (GRA) launched a Special Voluntary Disclosure programme on the back of AEOI data, which is reportedly influencing taxpayer behaviour, and generating revenue. For instance, GH¢900.6 million (Ghanaian Cedis) (around US$75 million) was raised from the programme as at December 2024. The experts view tax transparency as integral to Ghana’s vision of making Accra a regional financial hub.
In transfer pricing, Ghana has made significant strides, beginning with the 2012 introduction of regulations (L.I. 2188) to address transfer mispricing and align with global standards. These were updated in 2020 with L.I. 2412 to incorporate Action 13 of the Base Erosion and Profit Shifting Project (BEPS), further strengthening compliance. The Transfer Pricing Unit is now seen as a major revenue driver, though improvements are still needed in staffing, training, and incentives. In contrast, Ghana has yet to introduce a digital services tax or significant economic presence regime, and an Electronic Transfer Levy (E-levy) targeting some domestic digital transactions, which was introduced in 2022, has been abolished by the Electronic Transfer Levy (Repeal) Act 2025 (Act 1127). Ongoing debate over legislative approach has delayed action, leaving VAT on non-resident digital services, introduced in 2022, as the sole tax on digital services in the country.
