Ghana has made it mandatory for Multinational Enterprises (MNEs) operating in the country, that meet specific revenue thresholds, to provide detailed information on their worldwide operations through Country-by-Country Reporting (CbCR).
MNEs are required to include the following information in their CbCR:
- Aggregated information on revenue, profit or loss before income taxes, stated capital, accrued income taxes, paid income taxes, accumulated earnings, workforce, and tangible assets across different jurisdictions.
- Detailed profiles for each Constituent Entity, including primary business operations, tax residence, and jurisdiction of incorporation.
- Any additional information deemed necessary by the Commissioner-General (CG) of the Ghana Revenue Authority (GRA).
A Multinational Enterprise (MNE) Group generating a total consolidated revenue of at least GHS 2.9 billion in the fiscal year before the Reporting Fiscal Year must prepare and submit a Country-by-Country Report (CbCR).
The CbCR should be submitted using a form that complies with definitions and guidelines provided in the Transfer Pricing Practice note DT/2021/003 (Appendix 3) published by the Ghana Revenue Authority (GRA) on 15 April, 2021.
The deadline for submitting the CbCR to the CG is no later than 12 months after the final day of the MNE Group’s Reporting Fiscal Year.
Consequences of failing to submit CbCR
Any MNE Group failing to submit the CbCR to the CG by the prescribed deadline will be penalised a GHS 500 fine, plus a daily surcharge of GHS 10 for each day the submission is delayed.
Company directors will be imposed with a fine ranging between GHS 12,000 to GHS 30,000; imprisonment for two to five years; or both.
