This study assesses the development and implementation of rules to monitor transfer pricing in the mining sector in countries with varied experiences. Based on analysis of these recurring challenges, this publication contains a number of recommendations that would help Ghana, Guinea, Sierra Leone, Tanzania, Zambia and other countries in similar contexts to better address transfer pricing risks in the mining sector through the application of the arm’s length principle. This publication presents the results of a study on transfer pricing and the mining industry in Africa, with specific focus on the challenges to implementation of transfer pricing rules in five representative countries The study was undertaken in 2015 by Oxford University researcher Alexandra Readhead, in partnership with the Natural Resource Governance Institute (NRGI). It builds on NRGI’s existing work in extractive industry fiscal regime design by responding to concerns from many African countries that government revenues have not kept up with the development of extractive activities, particularly during the commodity super cycle. It called on staff of the Transfer Pricing Unit at the Ghana Revenue Authority (GRA), to have specialized audit training to fight tax avoidance and transfer pricing, particularly in the extractive industry. The report reveals that companies take advantage of inadequate and weak tax administration in developing countries to engage illicit financial flows which costs the countries millions of dollars every year.