articles

Understanding Ghana’s change in ownership rules

In this article, we argue that moving shares of a Ghanaian company to another company within a group does not qualify for a tax exemption. This transaction must be taxed. Why must Ghanaian companies pay taxes when there is a 50% change in their underlying ownership? Why do they lose their tax losses from the past? Why must they revalue their books whenever a new underlying owner comes on board? We answer all these questions in this article.

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Why an appeal against the High Court’s ruling in the FBC Partners v GRA case must succeed

The High Court set the time of supply to be the date of the initial agreement. The court did not consider any of the time of supply rules in the VAT law. The contract date is irrelevant in determining when VAT is due. In this article, we review the statutory rules and point out what the court should have done.

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The GRA does not need to pre-approve tax treaty benefits

Did you know the GRA’s new ITAS platform demands pre-approval before you can apply a double tax treaty rate?

While the GRA wants to prevent treaty abuse, the law doesn’t actually give them the power to dictate withholding rates before a return is filed. The responsibility (and liability) belongs to the withholding agent. Read our latest article on why this new administrative procedure lacks legal backing and could face a judicial review action.

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Why the Ex parte Agility case must be reversed

The Court of Appeal’s decision in Agility v. GRA fundamentally alters Ghana’s VAT landscape by allowing general refunds for excess input VAT, a process historically restricted to credits and specific exceptions like exporters. By endorsing a judicial review path (Mandamus) and merging distinct refund “streams” under Section 50 of Act 870, the ruling challenges established Supreme Court procedural precedents and threatens the liquidity of the national tax system.

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Ghana’s new VAT law removes consumption-based zero-rating of services

Before 2026, there were four different VAT rates in Ghana. We had two flat rates, made up of 3% for some retailers and 5% for the real estate sector. There was also the standard rate of 15% and a rate of 0%. The new VAT law has abolished the flat rates. It has also modified, even if unintentionally, the way some services are considered for zero rating.

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Communications Service Tax on Imported Services

Communications Service Tax is a tax that is imposed on electronic communications services. The tax authority expects any user of the electronic communications to pay the tax whenever the electronic communications service is provided from outside Ghana. This practice is inconsistent with the law. This article discuses what the law says and why the tax authority needs to update its Administrative Guidelines and audit methodology.​

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The new VAT regime for supply of services

The Value Added Tax Act, 2025 (Act 1151) came into force on 1 January 2026. It came with some reforms such as removing the GETFund and NHI levies from the base of the calculation of the VAT and allowing deduction of the input GETFund and NHI levies. The effect of all the reforms taking effect in 2026 is the reduction of the effective tax rate from 21.9% to 20%. One major reform which does not benefit taxpayers is the removal of threshold for services. This article discusses the unexpected change.

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