Ghana Revenue Authority To Automate Treaty Applications

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Ghana Revenue Authority (GRA)
Ghana Revenue Authority (GRA)

The Ghana Revenue Authority plans to fully automate how taxpayers and multinationals apply for double taxation treaty benefits, a reform it says will cut compliance costs and speed up approvals.

Nana Mensah Otoo, who heads the GRA’s International Tax Office, said digitising the process would make treaty benefits easier to access and bring more certainty for cross border investors. He told a webinar hosted by the UK Ghana Chamber of Commerce and PwC Ghana that taxpayers would still need GRA approval before enjoying treaty reliefs.

Applications often stall, Otoo said, because taxpayers leave out contract details or documents such as withholding receipts, while verifying residency certificates with treaty partners can also drag on. Automation, he added, should ease those delays.

He also signalled bigger changes ahead. Ghana plans to amend its income tax laws to tax digital assets and to introduce a significant economic presence test, capturing income from remote and digital services that current rules on permanent establishments miss.

On the wider stage, a Finance Ministry technical adviser, Daniel Nuer, said a United Nations Framework Convention on International Tax Cooperation was being drafted for the UN General Assembly’s 82nd session from September 2027. Ghana, which has initiated 36 double taxation agreements and has 14 in force, including with Britain, Germany, France, the Netherlands and Belgium, has also signed an ECOWAS treaty awaiting parliamentary ratification.

Tax practitioners flagged slow dispute resolution, warning that cases dragging on for years would undercut the certainty treaties are meant to provide. Otoo said the Authority balanced enforcement with investment promotion. “We are investment pro,” he said, explaining why it sometimes reviews contracts before approving treaty benefits.

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