GRA serves audit notice on Jonathan Alua’s firm after baggage exemption suit

The Ghana Revenue Authority (GRA) has served an audit notice on the law firm of legal practitioner Jonathan A. Alua, days after he challenged the Authority’s powers over passenger baggage exemptions from customs duties and taxes.

The firm has been selected for a tax audit covering the 2023 to 2025 tax years, according to a report by 3news on Thursday, September 10, 2026.

The audit will cover Corporate Income Tax (CIT), Withholding Tax (WHT), Pay-As-You-Earn (PAYE), as well as Value Added Tax (VAT), National Health Insurance Levy (NHIL) and Ghana Education Trust Fund (GETFund).

“The GRA has assigned a three-member team to conduct the exercise,” the report said.

However, the Authority made clear in its notice that the audit was not an indication of any wrongdoing by the law firm.

“The notice does not suggest you have done anything wrong,” it stated, adding that it was being conducted in accordance with the provisions of the tax laws.

'You can only carry 2 phones into Ghana, anything more; you will pay duty - GRA

The notice comes shortly after Alua invoked the original jurisdiction of the Supreme Court to challenge Regulation 18(2)(b) of the Exemptions Regulations, 2025 (L.I. 2514).

The regulation empowers the GRA Commissioner-General to determine the quantity of passenger baggage that qualifies for exemption from customs duties and taxes.

Alua argues that the discretion granted to the Commissioner-General amounts to a waiver or variation of tax and therefore requires prior parliamentary approval under Article 174(2) of the 1992 Constitution.

He is seeking a declaration that the provision is unconstitutional to the extent that it permits the Commissioner-General or Customs officers to grant or refuse baggage exemptions on a case-by-case basis without prior parliamentary approval.

He is also asking the Supreme Court to restrain the GRA from exercising the disputed power until the constitutional requirements are satisfied.

The legal action followed public controversy over the treatment of mobile phones and other personal effects carried into Ghana by air passengers.

The GRA has since clarified that carrying more than two mobile phones does not automatically attract customs duty, explaining that Customs officers consider factors including the nature and quantity of the phones, whether they are new or used, their packaging and whether they appear intended for commercial purposes.

MRA/BAI

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