In Ghana, taxpayers who disagree with decisions made by the Ghana Revenue Authority (GRA) have a structured process to seek redress. The Revenue Administration Act, 2016 (Act 915), as amended by the Revenue Administration (Amendment) Act, 2020 (Act 1029), governs these rights. Tax administration is not a one-way process; it empowers GRA to assess and collect taxes while protecting taxpayers' rights to challenge decisions they consider incorrect or unfair. Understanding this process is essential for individuals, businesses, and tax advisers to ensure legitimate cases are not undermined by procedural errors.
A tax dispute arises when a taxpayer disagrees with a formal decision taken by GRA, such as an assessment of tax payable or refusal of a tax refund. However, not every engagement with GRA constitutes an appealable decision. Taxpayers must identify the specific decision being challenged and the amount in dispute. There are four categories of tax assessments: self-assessments, pre-emptive assessments, adjusted assessments, and assessments issued by the Commissioner-General. Taxpayers who believe an assessment is wrong have a statutory right to challenge it.
Objecting to the Commissioner-General is the compulsory first step in resolving a tax dispute. A taxpayer must submit a written objection within 30 days of notification of the tax decision. The objection must clearly identify the decision being challenged, state the grounds of objection, and provide supporting documentation. A general assertion that an assessment is excessive is insufficient; the taxpayer must demonstrate why the decision should be reconsidered. Additionally, taxpayers must pay all outstanding taxes, including the full disputed amount for import duties and taxes, or all outstanding taxes plus 30 per cent of the disputed tax for other taxes.
Once a taxpayer lodges an objection, the Commissioner-General has 60 days to issue a decision. If no decision is issued within that period, the taxpayer may treat the objection as disallowed and proceed to appeal. Taxpayers are entitled to only one objection to a tax decision. The Supreme Court clarified in Seadrill Ghana Operations Ltd v. Commissioner-General that a revised objection decision does not create a fresh right to object. Continued correspondence or meetings with GRA do not automatically extend the appeal period.
The establishment of the Independent Tax Appeals Board (ITAB) represents an important reform in Ghana's tax dispute resolution system. ITAB was introduced as an independent, less adversarial intermediate appellate body to provide a more accessible avenue for resolving tax disputes before they reach the courts. Although initially inaugurated in January 2023, the Board remained non-functional until its operationalisation was announced on November 13, 2025.
A taxpayer dissatisfied with an objection decision must appeal to ITAB within 30 days of receiving that decision. The appeal is initiated by filing a Notice of Appeal with the Executive Secretary of the Board, together with the relevant tax decision and the original objection and Commissioner-General's objection decision. GRA is given an opportunity to respond before the Board considers both sides and delivers its determination.
ITAB provides an important layer of independent scrutiny outside GRA and offers more specialised, accessible dispute resolution. However, an appeal to the Board does not automatically suspend tax collection or enforcement. Where enforcement action is imminent, taxpayers may need to apply for a stay of execution or other appropriate relief. Understanding the tax dispute resolution process is crucial for taxpayers to ensure their rights are protected and legitimate cases are not undermined by procedural errors.
Key points
- Taxpayers in Ghana have a structured process to seek redress for tax disputes, governed by the Revenue Administration Act, 2016 (Act 915) and the Revenue Administration (Amendment) Act, 2020 (Act 1029).
