Hiding in Plain Sight: Trade Misinvoicing and the Impact of Revenue Loss in Ghana, Kenya, Mozambique, Tanzania, and Uganda: 2002-2011

A May 2014 Report from Global Financial Integrity




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Study: Ghana, Kenya, Mozambique, Tanzania and Uganda- This report analyzes trade misinvoicing in depth from five African countries over the period 2002-2011.


Media Resources

Press Release: African Countries Lose Billions Through Misinvoiced Trade - May 11, 2014




Clark Gascoigne


+1 202-293-0740 ext 222


E.J. Fagan


+1 202-293-0740 ext 227


Funding for this research was generously provided by the Ministry of Foreign Affairs of Denmark.


About the Authors


Raymond Baker, President of Global Financial Integrity. Read more about Mr. Baker...


Christine Clough, Senior Program Officer at Global Financial Integrity. Read more about Ms. Clough...


Dev Kar, Chief Economist at Global Financial Integrity. Read more about Dr. Kar...


Brian LeBlanc, Junior Economist at Global Financial integrity. Read more about Mr. LeBlanc...


Joshua Simmons, Policy Counsel at Global Financial Integrity. Read more about Mr. Simmons...

Primary Findings

Between 1980 and 2009, Ghana, Kenya, Mozambique, Tanzania, and Uganda lost saw US$60.8 billion move illegally in or out of their countries from trade misinvoicing.


The five countries lost a tremendous amount of government revenue due to trade misinvoicing. Uganda led the group with an estimated loss of 12.7% of total government revenue, followed by Ghana (11%), Mozambique (10.4%), Kenya (8.3%) and Tanzania (7.4%).


Policy Recommendations

The report recommends several policies to combat trade misinvoicing, including:


  • Governments should significantly boost their customs enforcement, by equipping and training officers to better detect intentional misinvoicing of trade transactions;
  • Trade transactions involving tax haven jurisdictions should be treated with the highest level of scrutiny by customs, tax, and law enforcement officials;
  • Government authorities should create central, public registries of meaningful beneficial ownership information for all companies formed in their country to combat the abuse of anonymous shell companies;
  • Financial regulators should require that all banks in their country know the true beneficial owner of any account opened in their financial institution;
  • Ghana, Kenya, Mozambique, Tanzania, and Uganda should actively participate in the worldwide movement towards the automatic exchange of tax information as endorsed by the G20 and the OECD;
  • Kenya and Uganda should follow the lead of Ghana, Mozambique, and Tanzania in joining and complying with the Extractives Industry Transparency Initiative (EITI); and
  • Government authorities should adopt and fully implement all of the Financial Action Task Force’s anti-money laundering recommendations.



GFI Chief Economist Dev Kar and GFI Junior Economist Brian LeBlanc developed robust economic models that highlight the drivers and dynamics of illicit flows in both directions for each of the five countries analyzed.  Nevertheless, GFI cautioned that their methodology is very conservative and that there are likely to be more illicit flows into and out of these countries that are not captured by the models.


GFI notes that—due to data issues, varying customs rates by commodity and sector, and various other factors—it is difficult to assess the true tax revenue loss stemming from trade misinvoicing in a particular country. The tax loss figures presented in this study are rough estimates of the possible impact that trade misinvoicing could have on government revenues in Ghana, Kenya, Mozambique, Tanzania, and Uganda.






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