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Ghana Tax Practice Notes, Guidance and Rulings

Search issued and published GRA practice notes, separate statutory interpretation from administrative guidance, follow supersession history and understand what private or class rulings can legally do.

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Administrative-authority research stewardship · Michael Siaw Larbi

Practice-note records29Guidance records15Public class-ruling indexNot located on GRA’s public siteCurrent-law statusReviewed

44 indexed records

Legal effect

Four document classes, four different questions

Practice note

Sections 100–102: binds the Commissioner-General until revoked; does not bind taxpayers.

Administrative guidance

A manual or guideline is not automatically a section 100 practice note merely because GRA publishes it.

Private ruling

Sections 103–106: transaction- and applicant-specific; served on the applicant and ordinarily not public.

Class ruling

Sections 103–106: applies to the identified class and arrangement; the Commissioner-General must make it publicly available.

Statutory interpretation

GRA practice notes

The repository records both notes available on GRA’s public index and issued GRA copies preserved by TaxLawGH. Inclusion does not assume that every earlier-law proposition remains current. Each reader identifies its reference, issue date, source status, stated authority and any material current-law qualification.

Income tax

Bank Business

DT/2016/009 · 6 October 2016

The income-tax treatment of banking business under Act 896.

Income tax

Capital Allowance

DT/2016/010 · 6 October 2016

Capital allowances for depreciable assets, including pooling, classes, realisation and sector rules.

Income tax

Carry Over Losses

DT/2016/004 · 6 October 2016

The carry-forward and use of unrelieved losses under the version of section 17 addressed by the note.

Income tax

Change in Accounting Date

DT/2016/007 · 6 October 2016

The income-tax process and consequences associated with changing an accounting date.

Income tax

Change in Ownership

DT/2016/008 · 6 October 2016

The continuity, realisation and loss consequences considered by GRA when ownership changes.

Exemptions

Charitable Organisation

DT/2016/002 · 6 October 2016

GRA's interpretation of the income-tax rules for charitable organisations.

Cross-border

Obtaining Double Taxation Relief

GRA/AG/2024/002 · 24 March 2024

GRA's administrative route for obtaining foreign-tax and treaty relief under Act 896.

Excise

Excise Duty

Not stated on the published note · 25 September 2025

GRA's interpretation and administration of the excise-duty framework addressed in the 2025 note.

Deductions

Final Limitation of Financial Cost

DT/2016/011 · 6 October 2016

The final limitation applied to financial-cost deductions under the statutory position addressed by the note.

Income tax

Minimum Chargeable Income

GRA/AG/2024/001 · 20 March 2024

The application of minimum chargeable income under Act 896, including the statutory tests discussed by GRA.

Mining

Separate Mineral Operation

DT/2016/014 · 6 October 2016

The ring-fencing of separate mineral operations and the allocation of income, expenditure, assets and liabilities between them.

VAT history

VAT Flat Rate Scheme

IDT/2017/001 · 12 May 2017

The VAT flat-rate framework under repealed Act 870. This is a historical note, not a statement of the current VAT Act 1151 position.

Withholding

Withholding of Tax

DT/2016/001 · 6 October 2016

GRA's interpretation of withholding obligations under the version of Act 896 addressed by the note.

Deductions

Bad Debts

DT/2020/002 · 28 April 2020

The requirements for deducting bad debts under the statutory position addressed by the note. GRA republished this 2020 note in its July 2026 upload directory.

Employment

Clothing Allowance

DT/2020/001 · 28 April 2020

The income-tax treatment of cash clothing allowances and clothing that is not suitable for wearing outside work.

Procedure

Extension of Time for Paying Tax

RAA/2020/02 · 30 April 2020

The application, conditions, approval thresholds and default consequences for an extension of time to pay tax.

Procedure

Accepting Security

RAA/2020/03 · 30 April 2020

The forms, conditions, surety, release, validity and enforcement of security accepted for a tax-law obligation.

Refunds

Payment of Tax Refund

RAA/2020/05 · 30 April 2020

The application, verification, decision, offset, payment and interest stages for tax refunds.

Payments

Order of Paying Tax

RAA/2020/06 · 30 April 2020

GRA’s stated administrative order for allocating a payment that is insufficient to discharge multiple tax liabilities.

Administration and operations

Guidelines, instructions and manuals

These records are classified separately because publication or operational usefulness does not by itself give a document the legal effect of a statutory practice note.

Historical levy guidance

Electronic Transfer Levy Administrative Guidelines

Earlier-law publication — verify the governing Act before use

Open the official GRA document ↗

Transaction-specific authority

Private, class and Customs advance rulings

No public GRA class-ruling index was located

TaxLawGH checked GRA’s public practice-note library, site search and advance-ruling material on 15 August 2026. No official public index of domestic-tax class rulings was located. That does not establish that no class ruling has been issued; section 105 requires an issued class ruling to be made publicly available.

Before issue

An application must describe the arrangement and relevant tax question.

Binding scope

The ruling binds only within the applicant or class, arrangement, period, law and assumptions identified.

Change or revocation

Section 106 permits amendment or revocation; later inconsistent legislation prevails to the extent of inconsistency.

Customs route

GRA separately offers advance rulings for tariff classification and origin. Its completion instructions are application guidance, not published rulings.

Read Act 915 sections 103–106 ↗ · GRA advance-ruling guidance ↗ · GRA advance-ruling FAQs ↗

Source preservation

TaxLawGH retains verified copies of the source PDFs in this library so a broken government URL does not erase the research record. Where a source remains on GRA’s site, the reader links there. Where an issued copy is not presently listed on GRA’s public index, the reader says so and does not substitute a secondary host.

Open GRA’s official practice-note library ↗ · Open the Compliance and Procedure Engine

MSL Business School

TaxLawGH is an MSL Business School legal research resource.

The repository preserves source, classification, history and legal effect without treating every GRA publication as legislation.

Verified answers

Legal effect and ruling procedure

Use these answers to distinguish legislation, statutory practice notes, private rulings and Customs advance-ruling guidance.

Can a practice note change an Act?

No. Legislation controls. Later inconsistent legislation revokes the note to the extent of the inconsistency.

Can a taxpayer object to a private ruling?

The ruling itself is not subject to challenge, but a later tax decision for the arrangement may be challenged.

Does a GRA practice note bind a taxpayer?

No. Act 915 says it binds the Commissioner-General until revoked but does not bind persons affected by a tax law.

How long does a Customs advance ruling take?

GRA's public FAQ states within 90 days when all required documentation is complete.

What Customs advance rulings are currently available?

GRA currently identifies tariff-classification and rules-of-origin rulings.

When does a private ruling bind GRA?

Only where there was full and true disclosure, the arrangement proceeds materially as described, the document is properly headed and the stated period applies.