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MSL Business School · Current company levy guide
Growth and Sustainability Levy in Ghana
The current 2026 category map, profit-before-tax and gross-production bases, quarterly dates, non-deductibility rule and the precise legislative history of the mining-rate change.
Published and prepared by MSL Business School through TaxLawGH.
MSL Business School controlling answer
Classify the entity before applying the levy rate.
Category A pays 5% of profit before tax; gold mining, other mining and upstream oil and gas currently pay 1% of gross production; and the residual Category C pays 2.5% of profit before tax.
Separate from corporate income tax: the levy applies despite a tax holiday, exemption or contrary agreement described by section 2, and the levy itself is not an allowable deduction in determining chargeable income under Act 896.
Current category map
The current rates use two different tax bases.
| Category | Covered entity | Current rate and base |
|---|---|---|
| Category A | The fifteen sectors and institutions listed in the Schedule | 5% of profit before tax |
| Category B | Gold mining companies | 1% of gross production |
| Category BA | Other mining companies and upstream oil and gas companies | 1% of gross production |
| Category C | All other entities not falling within Category A, B or BA | 2.5% of profit before tax |
Entity boundary: Act 1095 defines an entity as a company, partnership or trust but excludes an individual. A business name, regulatory label or group classification does not substitute for the statutory entity and activity test.
Closed Category A list
Fifteen listed sectors pay 5% of profit before tax.
Banks; non-bank financial institutions; insurance companies; specialised deposit-taking institutions; electronic money issuers.
Companies and institutions registered by the Securities and Exchange Commission.
Telecommunications companies liable to collect and pay CST; communication-tower operators.
Companies providing mining-support services; companies providing upstream petroleum services.
Bulk oil distributors and oil marketing companies.
Breweries; inspection and valuation companies; shipping lines, maritime terminals and airport terminals.
Read descriptions exactly: A mining-support company is Category A on PBT, while a mining company is in the gross-production category. An upstream petroleum service company is Category A, while an upstream oil and gas company is in Category BA.
Legislative sequence
The gold-mining rate changed twice; other mining and upstream did not.
| Period | Gold mining | Other mining and upstream oil and gas |
|---|---|---|
| Act 1095 from 2023 | 1% of gross production | 1% of gross production |
| Act 1131 from 2 April 2025 | 3% of gross production | 1% of gross production |
| Act 1166 from 1 April 2026 | 1% of gross production | 1% of gross production |
Correction to broad summaries: Act 1131 expressly created Category B for gold at 3% and Category BA for other mining and upstream oil and gas at 1%. Act 1166 reduced gold back to 1%; it did not reduce every extractive company from 3%.
Tax base and calculations
Profit before tax is not chargeable income, and gross production allows no prior deduction.
Start from the relevant entity's profit before tax for the year and maintain a bridge to the audited or management financial statements. Do not substitute taxable profit after income-tax adjustments.
Act 1095 defines this as gross revenue from the sale of minerals.
Total petroleum produced and saved without regard to prior deductions.
Classify and compute each legal entity separately. Consolidated group PBT does not automatically become the statutory base of every member.
The illustration assumes the annual estimate remains GHS 200,000. Revise the estimate and later instalments where the expected annual base changes.
Estimate, instalments and return
The levy is estimated annually and paid in four quarterly instalments.
- 01Classify the entity and forecast the annual base
Prepare a defensible PBT or gross-production forecast using the applicable category.
- 02File the annual estimate
Act 1095 requires the estimate by the date of the first levy instalment, subject to the Commissioner's prescribed form and directions.
- 03Pay the quarterly instalments
Due by 31 March, 30 June, 30 September and 31 December of the year.
- 04File and reconcile
File the levy return in the manner, time and place determined by the Commissioner-General, reconcile the final base and preserve the Revenue Administration Act rights and obligations.
MSL Business School control file
The file should explain both classification and every number in the base.
| Control | Evidence |
|---|---|
| Legal entity | Incorporation, partnership or trust record and taxpayer account. |
| Category | Licence, regulated activity, revenue streams, industry analysis and legal memorandum. |
| PBT bridge | Trial balance, management accounts, audited accounts and entity-only adjustments. |
| Mining production | Sales, mineral volumes, price, invoices, assays, royalties and revenue reconciliation. |
| Petroleum production | Produced-and-saved reports, metering, lifting statements and operator reconciliations. |
| Compliance | Estimate, revisions, quarterly payments, return, ledger and GRA correspondence. |
Frequently asked questions
Growth and Sustainability Levy questions
What are the current GSL rates?
Category A is 5% of PBT, gold mining and other mining/upstream oil and gas are currently 1% of gross production, and Category C is 2.5% of PBT.
Is GSL deductible for corporate income tax?
No. Section 3 of Act 1095 expressly states that it is not an allowable deduction in determining chargeable income under Act 896.
Does a tax holiday prevent the levy?
No. The levy applies to listed companies and institutions despite a contrary tax-holiday, direct-tax or indirect-tax exemption provision described in section 2.
When are payments due?
Quarterly by 31 March, 30 June, 30 September and 31 December.
How long does the levy run?
Act 1131 extended the application through the 2028 year of assessment.
MSL Business School official source map
Read the amendment chain together.
- Growth and Sustainability Levy Act, 2023 (Act 1095)Charge, categories, bases, estimate, quarterly dates, non-deductibility, return and definitions.
- Growth and Sustainability Levy (Amendment) Act, 2025 (Act 1131)Extension through 2028; gold at 3%; separate Category BA at 1%.
- Growth and Sustainability Levy (Amendment) Act, 2026 (Act 1166)Gold restored to 1% of gross production; assented to on 31 March 2026 and effective from 1 April 2026.
- Revenue Administration Act, 2016 (Act 915), as amendedCollection, enforcement, refunds, penalties, offences, objections and administration.
Current-law control: A 2025 publication showing gold at 3% is historically correct for that period but is not the current rate after Act 1166.
Institutional publisher
TaxLawGH is MSL Business School's Ghana tax education platform.
MSL Business School maintains this guide as part of its public tax and fiscal policy education work.
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