Ghana Tax Case Library

Blue Sky Products (Ghana) Limited v Commissioner-General, Ghana Revenue Authority

A free-zone enterprise remained subject to the free-zone-specific 15% corporate rate after its tax holiday; the general 8% export rate did not displace that provision on these facts.

Why it mattersUseful for the specific-over-general approach to competing rate provisions and for free-zone enterprises, but the applicable First Schedule and Free Zones amendments must be checked for the income year in question.

Maersk Drillship IV Singapore Pte Ltd v Commissioner-General, Ghana Revenue Authority

The Court of Appeal sustained tax on profits attributed to Maersk's Ghana permanent establishment, but this result was set aside by the Supreme Court in 2025.

Why it mattersDo not rely on this decision as the current outcome of the Maersk dispute. It remains useful only for understanding the rejected lower-court reasoning and procedural history.

Maersk Drillship IV Singapore v Commissioner-General, Ghana Revenue Authority

A 3–2 Supreme Court majority enforced the project-specific petroleum agreement and treated the 5% withholding as final for Maersk's covered drilling income.

Why it mattersSupreme Court authority for this agreement and taxpayer. Apply cautiously: verify the exact petroleum agreement, ratification, beneficiary language, service relationship and fiscal-stability text before drawing any analogy.

Perseus Mining (Ghana) Limited v Commissioner-General, Ghana Revenue Authority

On the evidence, gold-forward losses were integrated with Perseus's mining business and the counterparties and contractual royalty recipient were independent parties.

Why it mattersImportant evidence-based authority on these particular hedges, counterparties and contractual royalties. It should not be reduced to a general rule that every hedge loss or private royalty is deductible.

Perseus Mining Ghana Limited v Commissioner-General, Ghana Revenue Authority

The Supreme Court dismissed GRA's appeal as a nullity because an administrative-origin appeal required special leave; it did not decide the tax merits.

Why it mattersStrong authority on the route to the Supreme Court from administrative-origin tax litigation. It is not authority approving the Court of Appeal's substantive analysis of hedges or royalties.

Richard Amo-Hene v Ghana Revenue Authority, Attorney-General & Judicial Service

The Supreme Court upheld the 30% payment condition for a tax objection and construed the court rule as yielding to the parent Act, avoiding a duplicate payment barrier.

Why it mattersStill important for statutory payment conditions and the hierarchy between an Act and procedural rules, but it describes the pre-ITAB litigation route and should not be used as a complete statement of today's appeal process.

Seadrill Ghana Operations Limited v Commissioner-General, Ghana Revenue Authority

Later correspondence did not restart the statutory appeal period after GRA's objection decision; the Court of Appeal treated the tax appeal as out of time.

Why it mattersA caution against treating negotiations or follow-up letters as a substitute for filing within the statutory period. Verify the current ITAB route and time limits for today's disputes.

Scancom PLC v Commissioner-General, Ghana Revenue Authority

The High Court upheld VAT apportionment for imported services supporting taxable telecom and exempt mobile-money activities, and treated the 2018 NHIL/GETFund levies as distinct non-creditable levies.

Why it mattersDirectly addresses Act 870 and the 2018 levy amendments for historical periods. Ghana's VAT legislation has since changed, so the current VAT Act and levy provisions must be applied to later transactions.

Unilever Ghana Limited v Commissioner-General, Ghana Revenue Authority

The High Court dismissed Unilever's appeal for want of jurisdiction because leave to appeal out of time was void; it did not decide the transfer-pricing merits.

Why it mattersAuthority on jurisdiction and deadlines, not on arm's-length pricing or the deductibility of marketing expenses. Check current ITAB and court-appeal procedures.

Republic v High Court (Financial and Economic Division), Accra; Ex parte Afia African Village Limited (Commissioner-General, Ghana Revenue Authority, interested party)

GRA's written refusal of a tax refund was a tax decision that had to pass through the statutory objection and appeal route before supervisory relief was sought.

Why it mattersImportant on characterising refund refusals and exhausting specialist tax remedies. The Court did not decide whether the underlying compulsory-acquisition compensation was substantively taxable.

John Deporres Ayimbire v Attorney-General & Ghana Revenue Authority

The Supreme Court rejected a constitutional challenge to integrating the former customs service into the GRA; it was not a taxpayer-assessment case.

Why it mattersHistorical constitutional authority about institutional integration. It should not be cited as deciding any taxpayer's customs valuation, assessment or liability, and the current Act 1096 must be consulted.

Export Finance Company Limited v Ghana Revenue Authority & Attorney-General

The Supreme Court upheld the appeal-rule payment provision but made it yield to the parent revenue statute, preventing a second payment after statutory compliance.

Why it mattersUseful for the hierarchy of enactments and against cumulative payment barriers, but not a complete statement of the current objection and ITAB appeal regime.

Kwasi Afrifa v Ghana Revenue Authority (constitutional reference)

In a constitutional reference arising from a tax appeal, the Supreme Court addressed the compatibility and operation of statutory and procedural payment conditions.

Why it mattersRelevant to legislative hierarchy and the historical payment-condition debate. Confirm current statutory text and the ITAB path before advising on a present appeal.

Kwasi Afrifa v Ghana Revenue Authority & Attorney-General

The Supreme Court rejected a broad constitutional challenge to Act 915, including attacks on the Commissioner-General's administrative powers, tax penalties and the taxpayer's civil burden of proof.

Why it mattersUse for the specific constitutional propositions the Court actually addressed, especially administrative tax power and section 92's civil burden. Consult the current Act 915 text and later case law for any live dispute.

Seadrill Ghana Operations Limited v Commissioner-General, Ghana Revenue Authority

The Supreme Court held that an objection decision cannot be challenged by serial objections and that later administrative correspondence did not restart the appeal period.

Why it mattersSupreme Court authority on sections 41–44 of Act 915. Check amendments and the present tribunal or court route before calculating a live deadline.

Beiersdorf Ghana Limited v Commissioner-General, Ghana Revenue Authority

The Court of Appeal treated Beiersdorf's appeal as competent and allowed its royalty deduction under Act 896, while preserving withholding tax on the payments.

Why it mattersImportant for separating deduction rules, registration consequences and withholding obligations. Verify current technology-transfer and withholding provisions.

Fan Milk Ghana Limited v Commissioner-General, Ghana Revenue Authority

The Court of Appeal held that Fan Milk's month-end volume incentives were commissions to sales agents, not cash discounts, and therefore attracted withholding tax.

Why it mattersLeading located appellate authority on distributor incentives and withholding. Contract labels alone are insufficient; price adjustment, control and payment function matter.

*Editorial date reconstruction: the available judgment prints ‘Wednesday, 27 February 2018’, but the appeal was filed on 10 April 2018. In addition, 27 February 2018 was a Tuesday, while 27 February 2019 was a Wednesday. TaxLawGH therefore provisionally records 27 February 2019 pending registry confirmation.

Eaton Towers Ghana Limited v Commissioner-General, Ghana Revenue Authority and Attorney-General

The High Court upheld GRA's adjustment of Eaton Towers' Vodafone tower arrangement after finding that the structure and pricing supported the avoidance assessment.

Why it mattersFact-sensitive first-instance authority. Test any current transaction against present anti-avoidance, transfer-pricing and VAT provisions.

Republic v Ghana Revenue Authority, Ex parte D.M. Kojo Trading Enterprise

A GRA garnishment notice was null because the taxpayer had not first been served with the assessment and afforded the statutory process and natural justice.

Why it mattersUseful for procedural fairness in tax recovery. Confirm the current Act 915 text and later cases before challenging a garnishment or third-party notice.

Multichoice Ghana Limited v Commissioner, Internal Revenue Service

Under repealed SMCD 5, subscription receipts invested at interest remained business income and qualifying television-business expenses were deductible from the aggregate.

Why it mattersThe interpretive principle remains influential, but the income-classification and deduction holding is historical and must not be applied as current legislation.

QG Ghana Hotel Holding Limited v Commissioner-General, Ghana Revenue Authority

The High Court upheld VAT on Ambassador Heights subleases after treating QG as an estate developer and finding its dwelling exemption and adjustment errors unproved.

Why it mattersFact-specific guidance on property supplies and exemptions. Check the VAT Act and amendments applicable to the transaction date.

Scancom Limited, Ghana Telecommunications Company Limited and Millicom Ghana Limited v Commissioner, Ghana Revenue Authority

The High Court held that one telecom operator was not another's consumer or subscriber and excluded interconnect charges from CST under the then Act 754.

Why it mattersHistorically important for interconnect charges, but current liability must be tested against amended CST legislation and later authority.

Orica Ghana Limited v Commissioner-General, Ghana Revenue Authority

The Court of Appeal affirmed that Orica's manufacture, transport and delivery of explosives formed one business and upheld authenticated photocopied VAT relief orders.

Why it mattersRecent appellate guidance on integrated business activities and documentary proof. It is not a blanket rule that every delivery service is manufacturing.

Republic v Commissioner-General, Ghana Revenue Authority, Ex parte Agility Distribution Parks Ghana Limited

The Court of Appeal held that admitted excess VAT had to be refunded under Act 915 and allowed mandamus; GRA could not indefinitely retain it as a credit.

Why it mattersRecent appellate authority on admitted excess VAT and mandamus. Check current refund regulations, set-off position and any further appeal.

Taylor & Taylor Ltd v Commissioner-General & Attorney-General

The High Court annulled an unserved assessment, rejected GRA's self-help collection and 30% late-filing penalty, and permitted a lawful fresh assessment.

Why it mattersValuable procedural authority, but the substantive provisions arose under Act 592 and amendments. Use current Acts 896 and 915 for present disputes.

M & C Logistics and Trading Limited v Iddrisu Ventures & Iddrisu Adams

The High Court held that the purchaser was the statutory withholding agent for gold payments, but dismissed its recovery claim because it proved neither the alleged private arrangement nor payment of the recoverable principal tax to GRA.

Why it mattersA useful modern explanation of the payer's role in precious-mineral withholding and the reimbursement mechanism after a failure to deduct. The 3% figure belonged to the transaction period; the applicable rate, mineral-trading rules and current text of Act 896 must be checked for a present payment.

Kenashmi Ghana Limited v Commissioner-General, Ghana Revenue Authority

The High Court awarded Kenashmi the proved value of four tomato-paste containers after finding that GRA entertained the valuation objection yet allocated or auctioned the goods before the required publication and without proof that they were returned.

Why it mattersA recent first-instance authority on customs-objection administration and the procedural order for auctioning goods. Its suspension analysis is fact-dependent and should be read with the current objection, security, clearance, forfeiture and auction provisions before use in a live matter.

The Republic v Havilah Oil Ltd, Lilian Acheampong, Nicholas Freduah Kwarteng & Kwame Otchere Darko

In an interlocutory criminal-tax ruling, the High Court rejected the third accused's no-case submission and called for his defence. It found only a prima facie case; it did not convict him or finally determine guilt.

Why it mattersUseful for the threshold applied to a no-case submission in a tax prosecution and for the possible evidential role of section 58 manager liability. It is not authority that the third accused was guilty or that every director is automatically criminally liable for an entity's unpaid tax.

Ouedraogo Hamed v Ghana Revenue Authority

The High Court held that a Burkina Faso-bound transit container became abandoned after the restored transit period expired, that gazetting supplied the required auction notice, and that warehouse-related payments did not change the customs procedure.

Why it mattersA detailed modern treatment of transit deadlines, restoration, abandonment and the difference between abandoned and seized goods. Its result turns on the unchanged transit procedure, the missed restored deadline and prior gazetting; different notice or entry facts may produce a different result.

James Afedo Foundation & James Kofi Afedo Esq. v Attorney-General, Commissioner-General, Ghana Revenue Authority & Speaker of Parliament

The Supreme Court upheld a preliminary objection and dismissed a challenge over taxes on menstrual-hygiene products because no real constitutional interpretation or enforcement issue had been established. The tax merits were not finally determined.

Why it mattersThe decision is important for the jurisdictional discipline required in constitutional tax litigation and for the limits of judicial remedies affecting taxation and the Consolidated Fund. Its underlying VAT dispute is historically bounded: Act 1107 zero-rated locally manufactured sanitary towels, and the Value Added Tax Act, 2025 (Act 1151), effective 1 January 2026, retained zero-rated treatment for locally manufactured sanitary towels. The decision does not establish that imported and locally manufactured products receive identical treatment, or that the merits of every menstrual-product tax are constitutionally settled.

Managing Director, Messrs African Distributors Company Ltd v Commissioner, Customs, Excise and Preventive Service (CEPS)

The Supreme Court dismissed two consolidated customs claims: the importer was bound by its written duty-settlement agreement, and it proved neither actionable duress nor customs negligence.

Why it mattersThe case remains useful on pleading duress, evidential estoppel, the legal effect of a written customs settlement and the need to frame grounds separately for distinct consolidated actions. Its customs-liability rule arose under repealed historical legislation, so present disputes must be tested under the current Customs Act, the Revenue Administration Act and any applicable regulations.

Republic v Commissioner-General, Ghana Revenue Authority, Ex parte Agility Distribution Parks Ghana Limited

The High Court refused mandamus compelling an immediate cash refund of excess VAT.

Why it mattersUseful as the displaced first-instance reasoning in the Agility refund litigation. Researchers should begin with the 2026 Court of Appeal judgment, not this ruling, when stating the current result. The ruling concerns mandamus and the interaction of the then-applicable statutory provisions. It is not the current appellate disposition.

Maersk Drillship IV Singapore Pte Ltd v Commissioner-General, Ghana Revenue Authority

The High Court rejected most of Maersk's requested declarations but held that GRA could not impose income tax outside the petroleum fiscal framework applicable to the OCTP project.

Why it mattersIt explains the factual and procedural foundation of the later Maersk appellate authorities. The High Court result is not the final appellate position. The Supreme Court record controls the current outcome.

Beiersdorf Ghana Limited v Commissioner-General, Ghana Revenue Authority

The High Court upheld GRA's revised assessment, including the denial of royalty deductions under an unregistered technology-transfer arrangement and withholding on reimbursements and claimed discounts.

Why it mattersThe pair of decisions separates royalty deductibility from withholding and shows why the appellate judgment must be read with the trial record. Do not cite the High Court's royalty or competency conclusion as the current result; both were materially reversed.

Bishop Daniel Obinim v Commissioner-General, Ghana Revenue Authority & Ecobank Ghana Limited

The Court dismissed a judicial-review challenge to GRA's third-party debtor notice.

Why it mattersA practical warning on service, objection deadlines and the limited role of judicial review in tax recovery. The reviewed copy does not state a suit number. The decision turns on the service and timing evidence before the Court.

Bishop Daniel Obinim v Commissioner-General, Ghana Revenue Authority & Fidelity Bank Limited

The Court held that a taxpayer cannot challenge an assessment and associated bank recovery by ordinary writ while bypassing the objection and appeal route in Act 915.

Why it mattersClarifies both the exclusivity of the statutory tax route and the sequencing of third-party debtor notices. It does not decide whether the underlying assessment was numerically correct.

Bumi Armada Ghana Limited v Commissioner-General, Ghana Revenue Authority

The High Court held that a 2014 private ruling continued to protect qualifying pre-revocation petroleum sub-subcontract arrangements and rejected withholding and PAYE treatment for the relevant manpower/service payments.

Why it mattersImportant for reliance on private rulings and transitional protection in petroleum taxation. The Court of Appeal removed the post-judgment auditor mechanism and its 2025 order must be used for the operative appellate result. The High Court face states 8 February 2022; a later appellate narrative refers to 5 February, so the certified face date is used with the discrepancy recorded.

Bumi Armada Ghana Limited v Commissioner-General, Ghana Revenue Authority

The Court of Appeal largely preserved the High Court's protection of qualifying arrangements under GRA's private ruling and the PAYE conclusion, but it set aside the independent-auditor/reconciliation order as an impermissible post-judgment delegation.

Why it mattersThe current located appellate authority in the Bumi line and a useful remedial-procedure decision. No later appellate disposition was identified in TaxLawGH's case-law review completed through 19 July 2026. That negative result does not prove that no appeal, unpublished order or unreported proceeding exists.

Center for Juvenile Delinquency v Ghana Revenue Authority & Attorney-General

The Supreme Court struck down the provisions that conditioned access to the courts on possession of a taxpayer identification number.

Why it mattersLeading constitutional authority on tax administration and access to justice. The decision did not invalidate TIN requirements generally; its ratio targets the court-access condition.

Chapel Hill School Limited v Attorney-General & Commissioner, Internal Revenue Service

The Supreme Court held that private ownership did not by itself prevent a school from being of a public character.

Why it mattersFoundational Ghanaian authority on the public-character concept for educational exemptions. The statutory provisions and corporate legislation were historical. Current exemption language and organisational facts must be checked afresh.

Coca-Cola Equatorial Africa Limited v Commissioner-General, Ghana Revenue Authority

The Court upheld withholding on trademark, accrual and 2017 incentive items, but reversed extra salary withholding, the 2018 incentive adjustment and VAT/levies on exported support services.

Why it mattersA useful multi-issue judgment on separating royalty, payroll, incentive and exported-service analyses. No later appellate disposition was identified in TaxLawGH's case-law review completed through 19 July 2026. That negative result does not prove that no appeal, unpublished order or unreported proceeding exists.

Fan Milk Ghana Limited v Commissioner-General, Ghana Revenue Authority

The High Court held that Fan Milk's distributors were agents and that month-end volume payments were commissions, not cash discounts.

Why it mattersProvides the trial record underlying the leading appellate treatment of distributor incentives. The Court of Appeal judgment is the stronger current authority and affirmed this result.

Hon. Clement Apaak v Ghana Revenue Authority

The Court upheld application of the VAT Flat Rate Scheme to importers who sold goods locally as wholesalers or retailers and rejected the discrimination challenge.

Why it mattersImportant historical transition authority on accrued VAT credits and classification of importers who resell. The flat-rate regime and rates have changed over time; use the case for principle only after checking current VAT legislation.

Kwasi Afrifa v Ghana Revenue Authority

The High Court refused human-rights and mandamus relief because the substance was a contested tax dispute requiring the prescribed procedure and factual adjudication.

Why it mattersExplains the procedural origin of the later Supreme Court payment-condition cases. The later Supreme Court decisions control the constitutional and appellate consequences.

Kwasi Nyantakyi Owiredu v Commissioner-General, Ghana Revenue Authority

The Court held that an employee who proves qualifying mortgage-interest payments on a sole residence can receive the statutory deduction through employer payroll cash payments rather than waiting for an annual return.

Why it mattersA practical authority on payroll administration of the historical mortgage-interest relief. The governing mortgage-interest provisions have changed; verify the law for the current year before relying on the mechanism.

Meridian Port Services Limited v Commissioner-General, Ghana Revenue Authority

The Court held that Meridian's parliamentary tax exemption took effect when Parliament approved it on 7 June 2016.

Why it mattersStrong practical guidance on the effective date and temporal limits of parliamentary tax exemptions. No later appellate disposition was identified in TaxLawGH's case-law review completed through 19 July 2026. That negative result does not prove that no appeal, unpublished order or unreported proceeding exists.

Orica Ghana Limited v Commissioner-General, Ghana Revenue Authority

The Court treated Orica's explosive manufacture, storage, transport and delivery as one integrated business qualifying for the manufacturing location incentive.

Why it mattersThe full trial foundation for the 2026 appellate authority on integrated manufacturing and evidence. The Court of Appeal judgment should be cited for the final appellate confirmation.

Perseus Mining Ghana Limited v Commissioner-General, Ghana Revenue Authority

The High Court upheld GRA's treatment of related-party gold forward-sale arrangements and rejected deductions for hedging or investment losses against mining business income.

Why it mattersProvides the evidential record behind the leading Perseus appellate merits judgment. Use the 2023 Court of Appeal judgment for the current merits position; the 2025 Supreme Court record was procedural.

PIL Ghana Limited v Commissioner-General, Ghana Revenue Authority

The Court upheld accrual of demurrage commission and interest from the original due date, but reversed PAYE on a general staff lunch, VAT on exempt money-collection services and a penalty-related adjustment.

Why it mattersA current, detailed first-instance treatment of mixed direct and indirect tax adjustments. No later appellate disposition was identified in TaxLawGH's case-law review completed through 19 July 2026. That negative result does not prove that no appeal, unpublished order or unreported proceeding exists.

Republic v Commissioner-General, Ghana Revenue Authority, Ex parte Cereal Investment Company Ghana Limited

The Court held that the taxpayer had not exhausted the statutory appeal route and dismissed most judicial-review relief.

Why it mattersA distinctive remedy-focused decision from the transition to the Independent Tax Appeals Board. The Board architecture and appeal route have evolved; verify present institutional arrangements before applying the order.

Republic v Ghana Revenue Authority, Ex parte Export Finance Company Limited (Universal Merchant Bank Limited, interested party)

The Court dismissed judicial review of GRA's objection decision and garnishment.

Why it mattersSupplies the factual and procedural foundation for the Supreme Court's later constitutional treatment of objection payments. The reviewed copy states no suit number. The 2022 Supreme Court decision should be consulted for the later constitutional position.

Seadrill Ghana Operations Limited v Commissioner-General, Ghana Revenue Authority

The High Court struck out Seadrill's appeal as out of time. The valid objection decision was the December 2020 decision; continued correspondence and a later payment letter did not create a new objection decision or restart time.

Why it mattersThe first-instance ruling in a now-confirmed Supreme Court line on finality and deadline calculation. Use the 2026 Supreme Court judgment as the controlling appellate authority.

ACS Africa Coastal Services (Ghana) Limited v Ghana Revenue Authority

07 National Fiscal Stabilisation Levy assessment. Act 915 required a tax appeal, so the writ did not properly invoke the Court's jurisdiction and the merits were not reached.

Why it mattersA clear mode-of-commencement decision for statutory tax appeals. The Court expressly did not decide whether ACS was substantively liable to NFSL.

Republic v Commissioner-General, Ghana Revenue Authority, Ex parte African Mining Services (Ghana) Pty Limited

The Court refused judicial review of GRA's decision not to waive the 30% objection payment.

Why it mattersDetailed treatment of the scope and reviewability of GRA's objection-payment discretion. The case reviewed the refusal process, not the correctness of the underlying US$14.913 million assessment.

Ivy Morrison v Ghana Revenue Authority

The Court refused an interlocutory injunction against alleged preferential customs benchmark values.

Why it mattersUseful for interim-remedy standards in customs-policy litigation. This is an interlocutory ruling, not a merits judgment on benchmark valuation, discrimination or revenue loss.

Unilever Ghana Limited v Commissioner-General, Ghana Revenue Authority

The Court extended Unilever's appeal time because the operative objection decision was issued on 19 March 2020 and the COVID-19 lockdown interrupted the remaining filing period.

Why it mattersThe procedural gateway to Unilever's substantive transfer-pricing appeal and a practical deadline decision from the COVID-19 period. The ruling did not decide transfer-pricing merits. The later substantive judgment must be treated as a separate decision.

Scancom PLC v Commissioner-General, Ghana Revenue Authority

The Court reversed withholding assessments on payments to foreign carriers for international interconnect and roaming services.

Why it mattersA major telecommunications withholding authority on source and network apparatus. No later appellate disposition was identified in TaxLawGH's case-law review completed through 19 July 2026. That negative result does not prove that no appeal, unpublished order or unreported proceeding exists. The source provisions must be matched to the tax year and current legislation.