By Omar Bah
The Gambia Revenue Authority (GRA) has launched a hands-on transfer-pricing audit programme to sharpen its ability to detect tax risks, probe complex cross-border transactions and stop profit-shifting that erodes government revenue.
The Transfer Pricing Technical Assistance Mission and Practical Audit Support Programme, backed by the African Tax Administration Forum (ATAF) and the World Bank, moves the GRA from classroom theory to active enforcement by building specialised, operational capacity in transfer-pricing audits.
“This engagement is not the start of our transfer-pricing work; it is a critical next phase,” GRA Commissioner General Yankuba Darboe said. “We have already delivered theoretical training. Now we must translate that knowledge into audit action.”
Darboe said the programme will give officers direct, on-the-job support to assess transfer-pricing risks, select high-risk cases, plan audits and analyse complex transactions. The emphasis, he said, is clear: convert training into measurable skills and institutional capacity that deliver results.
“For a developing country like The Gambia, administrative weaknesses cannot become routes through which legitimate tax revenue is lost,” Darboe said. Strengthening the GRA’s transfer-pricing audit capability, he added, is essential to the country’s domestic revenue mobilisation strategy.
ATAF Transfer Pricing Specialist Betty Ahwera said the mission builds on a work plan launched in September and focuses now on practical casework. Five of seven planned activities are complete; the current mission covers the sixth, with the final activity scheduled for a follow-up mission.
“We are progressing from fundamentals to real, actionable cases,” Ahwera said. Using a risk-assessment framework developed in earlier sessions, officers will identify and select cases for transfer-pricing audits during this mission.
Ahwera praised the GRA’s Transfer Pricing Implementation Team for its dedication. “The team of 15–17 officers has shown strong enthusiasm and rapid learning,” she said.
ATAF specialist Robert Luvuuma said the practical programme will expose GRA officers to experienced practitioners and build essential investigative skills. “Effective transfer-pricing enforcement requires technical capacity, robust legislation and access to information,” he said.
Luvuuma emphasised the need for international exchange of tax information to trace cross-border financial flows. “In transfer-pricing work, you must ‘follow the money’—foreign data often reveals stark profitability gaps between related entities,” he said.
He also underscored practical skills: gathering evidence, conducting targeted interviews and asking incisive follow-ups. Luvuuma warned that stronger questioning may trigger taxpayer pushback—an indicator, he said, that auditors are probing correctly.
ATAF will continue support through regular case reviews and remote assistance. “We will engage weekly to review cases and participate in actual transfer-pricing audits,” Luvuuma said, committing sustained technical backing as the GRA moves from training to enforcement.

