How to win a tax dispute before it starts

Most taxpayers assume a tax dispute begins when an assessment lands on their desk. Not really! It begins much earlier. It could stem from an invoice that cannot be located, a difference that cannot be explained, a contract that does not support a tax treatment, or a tax return that cannot withstand scrutiny.

This means the problem started before the Ghana Revenue Authority (GRA) knocked on their doors. These seemingly minor issues grow into major weaknesses and result in assessments that are largely avoidable.

This is why tax dispute readiness should begin before the GRA raises the first question. So, how does a taxpayer win before the dispute begins? By building a defensible record before the audit.

That means: Retain complete and accessible records, as the law requires. Ensure tax filings reconcile with financial statements, ledgers and supporting documentation. Confirm that contracts reflect the underlying transactions as they occur, not after an audit begins.

Obtain timely advice, and where appropriate, engage formally with the tax authorities where uncertainty exists. Respond within agreed timelines when the audit begins. Document decisions and assumptions before memories fade or personnel change.

These practical steps are not merely good compliance practices. They are closely tied to what the law expects of taxpayers. Ghana’s Revenue Administration Act requires taxpayers to keep proper records, including invoices, receipts, vouchers and contracts for at least six years, and for longer in some special circumstances.

Even a technically correct position may fail if it is not adequately supported by evidence—evidence that is timely built, safely kept and able to withstand changes in personnel or management.

Without the necessary evidence, taxpayers may face not only an avoidable assessment but also an immediate cash flow burden. Where a dispute lingers up to the objection stage, the taxpayer must pay 100% of disputed import duties and taxes, and for other general taxes, 30 percent unless relieved.

This is why early preparation is not just a nice-to-do, but a must-do and a practical way to reduce the risk of costly disputes.

So here is the lesson, in tax disputes, preparation is the best strategy. Build your RECORD early, let it tell the right story, and you win the dispute before it starts.