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Tax
GRA tax audit and assessment support
When the Ghana Revenue Authority is already asking.
Support through a tax audit, an assessment or a demand: the correspondence, the evidence, the objection within the statutory window, and the negotiation. Deadlines here are short and unforgiving, which is why the first call matters more than the last.
Send us the assessment See what is includedA Ghana Revenue Authority review is a documentary process. It is won or lost on whether the records that support a position exist, can be found, and say what you believe they say. Very little of it turns on argument.
What we do first
Establish the scope: which tax types, which periods, which entity, and what has already been provided. Then we look at your position before we look at theirs, because the worst outcome in this work is discovering a second problem halfway through defending the first one.
Where the assessment is wrong, we say so and evidence it. Where part of it is right, we say that too. A defence that contests everything loses credibility on the points that actually matter, and officers notice.
The objection window
There is a statutory period within which an objection to an assessment must be lodged, and it is short. Missing it can leave you with a liability that is no longer contestable, however wrong it was. This is the single most common way a defensible position becomes an unarguable one.
If an assessment has landed, the date on it is the most important fact in the document. Send it to us before you do anything else, including replying.
When voluntary disclosure is the better route
Sometimes a review surfaces an error that predates it, or a client comes to us already knowing something is wrong. Approaching the Ghana Revenue Authority first is almost always better than being found, both in outcome and in tone. We will tell you plainly when that is the right course, even though it is a harder conversation than promising a fight.
What this is not
We do not promise outcomes. Anyone who tells you at the first meeting what an assessment will be reduced to has not read the file. What we can tell you quickly is how strong the position looks, what evidence would strengthen it, what the realistic range is, and what it will cost to pursue.
The Revenue Administration Act, which governs assessments and objections
Our first response when an assessment carries a deadline
What almost every successful defence is built from
Scope
From the first letter to the final position
Taken at any stage, though the earlier we are involved the more room there is.
Tax audit management
We handle the correspondence, manage information requests, attend meetings with the officers, and keep a record of everything provided. One route in and out, so nothing is conceded informally in a corridor conversation.
Assessment review and objection
Technical analysis of the assessment, identification of what is wrong and what is not, assembly of the supporting evidence, and the formal objection lodged within the statutory window.
Appeals and escalation
Where an objection is not resolved satisfactorily, escalation through the available routes, with a realistic assessment of prospects and cost before you commit to it.
Voluntary disclosure
Where an error is identified before the Ghana Revenue Authority finds it. Quantification, disclosure and negotiation of the settlement, which is normally a materially better outcome than discovery.
Payment negotiation
Where a liability is agreed but cannot be met at once. Instalment arrangements negotiated with a realistic schedule, because a default on an agreed plan is worse than not having one.
Post-audit remediation
Fixing what the review found so the next one is shorter. Process changes, withholding tax discipline, documentation standards and a compliance calendar that somebody owns.
Process
How we run a defence
A tax audit is a project with a fixed deadline and an opponent. It needs a plan, a single point of contact and a document trail.
Immediate triage
Same day. We read the letter or assessment, identify the deadline, confirm the scope and tell you what not to do next. Frequently this is the highest-value hour of the engagement.
Day onePosition review
Our own examination of the periods and tax types under review, before we respond to anything. We would rather find a second issue ourselves than have it emerge mid-defence.
Week 1 to 2Evidence assembly
Gathering and organising the documents that support the position. Where records are incomplete, we establish what can be reconstructed and what cannot, honestly.
Week 2 to 4Response or objection
The technical response or the formal objection, lodged within the statutory window, contesting what is contestable and conceding what is not.
Within the deadlineNegotiation
Meetings with the officers, technical exchanges, and settlement discussion where that is the right outcome. Realistic throughout about what is achievable.
OngoingRemediation
Once resolved, fixing the process that caused it. An assessment that recurs next year means the engagement only bought time.
After resolutionEngagement
Fees, timing and who does the work
Fee basis
Fixed fee by stageTriage and position review quoted first. The defence itself quoted once we know what we are defending. No open-ended hourly engagement.Who does the work
Partner-led throughoutMichael Siaw Larbi leads. Ghana Revenue Authority engagement is judgement work and it is not delegated to junior staff.Response time
Same dayWhere an assessment carries a deadline. Send it and call. Do not wait for a proposal before telling us it exists.Sectors
Where reviews concentrate
Interest withholding, financial services VAT and exempt supply apportionment.
Levy reconciliation, margins and import documentation.
Cross-border charges, permanent establishment and transfer pricing.
Import duty relief, promotional goods and distributor arrangements.
Subcontractor withholding, retentions and contract timing.
Exempt and taxable supply mix and consultant employment status.
Exemption status and withholding on grant-funded payments.
Director accounts, benefits in kind and personal expenditure.
First 48 hours
What to do the day the letter arrives
More positions are lost in the first week of a Ghana Revenue Authority review than in the whole of the rest of it. Not through dishonesty, but through helpfulness: handing over more than was asked for, answering a question outside the scope, or conceding a point in an email that later turns out to have been arguable.
- Withholding tax at the wrong rate, accumulated over years
- Expenses claimed without documentation that satisfies Act 896
- Benefits in kind not grossed up through payroll
- Bonus taxed wholly at graduated rates rather than the 5% band
- Input tax under-claimed since the 2026 VAT reset, or claimed on the wrong basis
- An exemption applied without a traceable legal basis
- Related party charges with no transfer pricing support
Questions
Questions when a review has opened
The GRA has written to us. What should we do first?
How long do we have to object to an assessment?
Can you reduce the assessment?
What if the assessment is actually right?
Should we make a voluntary disclosure?
Our records for that period are incomplete. Is it hopeless?
Can you help if another adviser has been handling it?
We cannot pay the liability in one instalment.
Next step
Send us the letter. Do not reply to it yet.
We will read it, tell you the deadline and the scope, and give you a view the same day. There is no charge for that first conversation.
Also under Tax
Corporate tax compliance and returns
Annual returns, quarterly instalments, capital allowances and the reconciliation between accounting profit and taxable profit, handled as a routine rather than as an annual emergency.
Transfer pricing under L.I. 2412
Documentation, benchmarking and the annual return under the Transfer Pricing Regulations 2020 (L.I. 2412), for businesses with related party transactions. And, before any of that, the harder question of whether the charge itself would survive a review.
VAT, NHIL and GETFund under Act 1151
VAT registration, monthly returns and the reconciliation between output tax, input tax and the ledger. Since Act 1151 took effect we have been reworking input tax positions, because the levies became claimable and most businesses are still treating them as a cost.
PAYE, SSNIT and expatriate tax
PAYE, SSNIT, Tier 3 relief, benefits in kind, bonus treatment and expatriate taxation. Payroll sits between finance and HR and frequently belongs to neither, which is exactly why officers look there first.
Exemption and incentive reviews
Tracing the basis of every benefit, exemption and concession you are applying, through the Exemptions Act 2022 (Act 1083), the applicable tax legislation and any approval that had to be given. Where the basis does not hold, we tell you before the Ghana Revenue Authority does.