International Journal of Management, Economics and Social Sciences
2026, Vol. 15(1-2), pp. 1 – 23.
e-ISSN 2304 – 1366
https://www.ijmess.com
DOI: 10.32327/IJMESS/15.1-2.2026.1

Transfer Pricing Regulation and Tax Revenue Performance in Ghana's Petroleum Sector: The Role of GRA Enforcement

Nuhu Alhassan Abdulrahman¹
Alhassan Bunyaminu²
Deborah Adu-Twumwaah³
Ibrahim Nandom Yakubu⁴
Adibura Baba Seidu⁵
Eunice Okyere⁶
Kingsley Oti^7
1,2,3 Dept. of Banking and Finance, University of Professional Studies, Accra, Ghana
⁴Dept. of Finance, School of Business, University for Development Studies, Tamale, Ghana
⁵Dept. of Accounting, University of Professional Studies, Accra, Ghana
⁶Dept. of Business, Southern New Hampshire University, New Hampshire, United States
⁷School of Economics and Management, Yanshan University, Qinhuangdao, China

This study examines the impact of transfer pricing regulations on petroleum tax revenue using the enforcement role of the Ghana Revenue Authority (GRA). Utilizing data from Ghanaian firms spanning 2002 to 2023 from reliable institutional sources including the GRA, PIAC, World Bank, and the U.S. Energy Information Administration, the study employs the Autoregressive Distributed Lag (ARDL) model to capture short- and long-term relationships, supported by the Generalized Autoregressive Conditional Heteroskedasticity (GARCH) model to address volatility in the residuals. The findings revealed that transfer pricing regulations exert a negative short-run impact on petroleum tax revenue but indicate potential long-run benefits as compliance improves. Audit recoveries demonstrated a significant and immediate positive effect, highlighting the importance of consistent enforcement. Additionally, oil price fluctuations and GDP growth were found to influence tax performance significantly. The findings of this study have important practical implications for tax policy, revenue administration, and regulatory strategy within Ghana’s petroleum sector and beyond. The evidence that transfers pricing regulations and audit recoveries significantly contribute to increased petroleum tax revenue demonstrates the effectiveness of strong enforcement mechanisms in curbing base erosion and profit shifting.

Keywords: Transfer pricing, petroleum tax revenue, Ghana Revenue Authority, ARDL model, GARCH model
JEL: G3, H2, H26, H3

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