Author(s): Mohammed Issah, Samuel Antwi, Zingteng Amatus
This study examines the effectiveness of international transfer pricing methods in the prevention of tax avoidance by multinationals in Ghana. Primary data was collected from 45 respondents comprising of 15 staff of the transfer pricing unit, 15 staff of the tax unit of tax multinationals and 15 multinationals using questionnaires and interviews. The responses were analyzed using a logistic regression model and descriptive statistics. To test the logistic regression model and evaluate the fitness of the model, the study adopted the Hosmer and Lemeshow test among several statistical methods (The pseudo R2, scale Deviance, Pearson goodness of fit chi-square test and information criteria among others). To ensure that tax officials and multinationals apply the right and effective transfer pricing method, the study found that government will have to train and retain staff of transfer pricing unit, the staff of the large taxpayers, Multinational Enterprises (MNE’s) and specialists, beef up the less than 20 staff in the transfer pricing unit, provide more financial and material resources. Ghana Revenue Authority (GRA) will also have to conduct a frequent audit using modernize audit policy and strategies, and provide a comparability database for transfer pricing in consultation with and support of other major stakeholders, as well as getting a specialist to support complex and prolonged audits of transfer pricing transactions. The study also concluded that difference in income tax among countries, import and export duties, interest and participation of local partners, restriction on profit and dividend repatriation, exchange rate risk, the political risk of nationalization of foreign companies and the relationship with the host government at a time are important variables/factors that MNE's consider when formulating transfer pricing policies and in deciding which transfer pricing method to adopt.