The Gambia Revenue Authority (GRA) has launched a technical assistance programme to strengthen its ability to identify and audit transfer pricing risks involving multinational companies and related-party transactions.
The Transfer Pricing Technical Assistance Mission and Practical Audit Support Programme receives support from the African Tax Administration Forum (ATAF) and the World Bank.
Opening the programme, GRA Commissioner General Yankuba Darboe said the initiative would move tax officers from theoretical knowledge to practical experience in conducting transfer pricing audits.
Darboe said GRA officers had already attended several physical and virtual workshops on transfer pricing principles, rules and concepts.
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However, he said understanding the principles was different from conducting an effective audit.
He said the latest phase would bridge that gap by providing direct practical support to tax officers.
The programme will cover transfer pricing risk assessment, case identification and selection, audit planning, transaction analysis and the practical steps needed to conduct effective audits.
Darboe described the programme as an important part of the GRA's broader strategy to strengthen domestic revenue mobilisation.
He said the Authority's ability to mobilise revenue depends largely on the competence, professionalism and technical capacity of its staff.
Under the GRA's Corporate Strategic Plan for 2025-2029, the Authority is investing in university programmes, professional qualifications and specialised training for its officers both within and outside The Gambia.
Darboe said the Authority should view such spending as an investment in its future and the country's development.
He also stressed the importance of partnerships with international organisations in specialised areas of taxation.
"Transfer pricing is one such area," he said.
Darboe said conventional academic and professional training must be complemented by practical experience from experts who have handled complex transfer pricing cases.
The programme brings GRA officers together with ATAF experts Betty Ahwera and Robert Luvuuma, both Transfer Pricing Specialists at ATAF. Benjamin from the World Bank is participating virtually.
Darboe said the practical nature of the programme would allow officers to examine actual transactions and audit issues while learning how experienced practitioners handle complex transfer pricing cases.
Darboe said stronger transfer pricing audits have become increasingly important as tax administrations face more sophisticated forms of tax non-compliance.
He warned that cross-border transactions, multinational corporate structures and related-party transactions could create opportunities for companies to shift profits between jurisdictions.
He said countries with limited technical capacity could lose significant tax revenue when weaknesses in tax administration go unchecked.
"The Gambia cannot afford to allow administrative weaknesses to become avenues through which tax revenues are lost," he said.
He said strengthening the GRA's ability to identify transfer pricing risks and conduct effective audits should form part of the country's wider domestic revenue mobilisation strategy.
Darboe commended ATAF for supporting African tax administrations in addressing illicit financial flows, base erosion and profit shifting, aggressive tax avoidance, tax evasion and other forms of non-compliance.
The programme also covers the country's transfer pricing legal and regulatory framework.
Darboe disclosed that ATAF, in collaboration with the World Bank, had shared draft Transfer Pricing Regulations with the GRA.
The draft regulations form part of the Authority's 2026 implementation work plan.
The GRA, working with the Ministry of Finance and Economic Affairs, will review the proposed regulations and provide comments.
Darboe said the GRA must strengthen its legal framework and administrative capacity at the same time.
He warned that sophisticated tax rules would have limited value if tax authorities lacked the expertise to enforce them.
Darboe urged members of the Transfer Pricing Implementation Team to take full advantage of the practical training.
He encouraged the officers to engage with the experts, ask questions and develop a strong understanding of transfer pricing audits.
He said officers should learn how to identify risks, select cases, request relevant information, analyse transactions, formulate audit questions and translate findings into defensible tax assessments.
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The GRA expects the programme to improve its ability to identify and conduct transfer pricing audits.
Darboe, however, said the knowledge gained should not remain with the officers participating in the programme.
He urged members of the implementation team to share their new knowledge and practical skills with other relevant officers within the Authority.
"This is how we build an institution," he said.
Darboe said the GRA's long-term goal is to make transfer pricing audits an established part of its compliance programme.
He expressed hope that GRA officers would eventually develop the confidence and technical competence to independently identify, investigate and address transfer pricing risks.
He said the partnership with ATAF and the World Bank goes beyond training individual officers. It also aims to build sustainable institutional capacity within the GRA.
Darboe formally declared the Transfer Pricing Technical Assistance Mission and Practical Audit Support Programme open and expressed hope for a productive and successful engagement.
