May 13, 2024 Ghana | Transfer pricing compliance required in Country-by-Country Reporting Multinational Enterprises (MNEs) operating in Ghana that meet a particular revenue threshold are required to provide detailed, comprehensive information on their global operations through Country-by-Country Reporting (CbCR). Definition of key terms Multinational Enterprise Group (MNE Group): An MNE Group refers to a collection of companies or entities operating in multiple countries, often under a common ownership or control structure. Ultimate Parent Entity (UPE): The UPE is the highest-level entity within an MNE Group that exercises control over other entities in the group. The UPE is typically the entity that consolidates the financial statements of the entire group. Constituent Entity: A Constituent Entity is any entity within an MNE Group, excluding the UPE, that forms part of the consolidated financial statements prepared by the UPE. Fiscal Year: A Fiscal Year refers to the annual accounting period with respect to which the UPE of the MNE Group prepares its financial statements. Reporting Fiscal Year: The Reporting Fiscal Year is the year that the MNE's financial statements and operational results reflect in the CbCR. Contents of CbCR In their CbCR, MNEs must include:
Who must file An MNE Group with total consolidated group revenue of at least 2.9 billion Ghana Cedis (GHS 2.9b) in the Fiscal Year immediately preceding the Reporting Fiscal Year is required to prepare and file CbCR. When and how to file
Criteria for Constituent Entity filing A Constituent Entity that is not the UPE of an MNE Group must file a CbCR if the following criteria are satisfied:
Multiple Constituent Entities MNE Groups with multiple Ghana-resident Constituent Entities can designate one entity to file, satisfying the filing for all and notifying the CG that the filing also applies for the other entities. Consequences of noncompliance Failure to file CbCR with the CG within the prescribed timeframe will result in:
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