By Fatou Krubally
The Gambia Revenue Authority (GRA) is strengthening its capacity to track profits across borders as it begins a practical transfer pricing audit programme with technical support from the African Tax Administration Forum (ATAF) and the World Bank.
The technical assistance mission, which opened Monday at the GRA Board Room, is aimed at moving GRA officers beyond theoretical training to the practical identification, selection and examination of transfer pricing cases.
GRA Commissioner General Yankuba Darboe said the latest phase marked an important stage in the authority’s transfer pricing capacity-building programme, following a series of physical and virtual workshops on the principles and concepts of transfer pricing.
He stressed that understanding transfer pricing principles was different from having the capacity to conduct effective audits, making practical support essential.
“The focus will therefore shift from the classroom to practical, hands-on audit work,” Darboe said.
The programme will support GRA officers in assessing transfer pricing risks, selecting suitable cases, planning audits, analysing transactions and applying practical procedures for effective transfer pricing investigations.
Darboe said the initiative formed part of the broader effort to strengthen domestic revenue mobilisation, noting that cross-border transactions, multinational corporate structures and dealings between related entities could create opportunities for profits to be shifted between jurisdictions.
He said weaknesses in tax administration should not provide opportunities for legitimate tax revenue to be lost.
“Strengthening our ability to identify transfer pricing risks and conduct effective transfer pricing audits must therefore form an important part of our broader domestic revenue mobilisation strategy,” he said.
ATAF Transfer Pricing Specialist Robert Luvuuma urged the GRA to strengthen its ability to trace financial transactions and obtain relevant information from other jurisdictions.
He described the approach as “follow the money”, saying access to information from foreign jurisdictions could assist tax authorities in determining whether profits declared in one jurisdiction correspond with the level of profitability recorded elsewhere.
Luvuuma said effective transfer pricing enforcement required technical expertise, sound legislation and improved access to information.
He also urged the authorities to fast-track proposed amendments to the country’s transfer pricing framework.
ATAF specialist Betty Ahwera said the technical team would use a risk assessment framework developed earlier in the programme to identify cases suitable for transfer pricing audits.
She said five of the seven activities outlined in the work plan had already been completed.
Ahwera said the mission would also examine issues related to the exchange of tax information, noting that The Gambia is not yet a signatory to the Convention on Mutual Administrative Assistance in Tax Matters, which could facilitate access to tax-related information from other jurisdictions.
Darboe disclosed that the GRA was also reviewing a draft transfer pricing regulation shared by ATAF and the World Bank.
He stressed that legal reforms and administrative capacity must advance together to ensure effective implementation.
“There is little benefit in having sophisticated rules if tax administration lacks the capacity to implement them effectively,” he said.
The Commissioner General urged officers participating in the programme to share the knowledge and practical skills acquired with other GRA staff, saying the ultimate objective was to build sustainable institutional capacity within the tax authority.
The mission is expected to provide continued physical and online support to GRA officers working on selected cases.
A non-disclosure agreement has also been signed to facilitate the experts’ access to relevant information required for the audit exercises.
Darboe said the GRA’s long-term objective was to make transfer pricing audits an established component of its compliance programme, with officers capable of independently identifying, investigating and addressing transfer pricing risks.
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