The Ghana Revenue Authority (GRA) has notified the law firm of legal practitioner Jonathan A. Alua of its intention to conduct a tax audit, barely a week after he commenced legal action against the authority and the Attorney-General at the Supreme Court.
The development comes amid a legal challenge by Mr Alua over the scope of powers granted to the GRA Commissioner-General to determine exemptions from customs duties and taxes on passenger baggage.
In a letter dated September 9, 2026, the GRA informed the law firm that it had been selected for a tax audit covering the period 2023 to 2025.
The notice was issued approximately one week after Mr Alua filed his case at the Supreme Court challenging a provision in the Exemptions Regulations, 2025 (L.I. 2514).
GRA says audit does not imply wrongdoing
In its letter, the GRA said the audit forms part of its mandate under Ghana’s tax laws.
The authority also sought to assure the law firm that its selection for the exercise should not be interpreted as evidence that it had committed any wrongdoing.
“This is to inform you that your company has been selected for audit under the provisions of the Tax Laws for the periods 2023-2025. We would like to assure you that this exercise does not suggest you have done anything wrong,” the letter stated.
The timing of the audit notice has, however, attracted attention because of its proximity to Mr Alua’s Supreme Court action.
Constitutional challenge
In his case before the Supreme Court, Mr Alua is seeking a declaration that Regulation 18(2)(b) of the Exemptions Regulations, 2025 (L.I. 2514) is unconstitutional.
His challenge centres on the powers granted to the GRA Commissioner-General under the regulation, particularly concerning the waiver or variation of taxes.
Mr Alua argues that the provision gives the Commissioner-General authority to waive or vary taxes without first obtaining approval from Parliament.
At the heart of the case is a broader constitutional question over the extent to which an administrative authority can exercise powers relating to taxation and exemptions without parliamentary approval.
The Supreme Court is expected to determine the constitutional issues raised by the challenge.
