MAERSK DRILLSHIP IV SINGAPORE PTE LTD.(SUING PER ITS LAWFUL ATTORNEY, JORGEN SCHAFFER) V. THE COMMISSIONER GENERAL GHANA REVENUE AUTHORITY

JUDGMENT

TANKO AMADU JSC: 

INTRODUCTION 

My Lords, the instant appeal has arisen out of a dispute over the assessment and imposition of tax from petroleum operations. In its simplest definition, tax is a compulsory levy imposed by the State on an individual or an entity for public purposes. The taxman and the taxpayer are two persons of significant interest to the State. Their common point of interest, is income generation or revenue for the State. While the taxpayer is expected to contribute to the development of the State through the payment of specified taxes, the taxman is enjoined to pursue the taxpayer to ensure compliance with tax obligations, albeit within specially structured and regulated mechanisms provided by law. 

Tax law is one area of law where enforcement and interpretation of regulatory provisions command strict construction. Under our constitutional and legislative regimes, unless the legislature or such other person empowered by the Constitution and relevant statute san…