PERSEUS MINING GHANA LIMITED V. COMMISSIONER GENERAL GHANA REVENUE AUTHORITY

RULING

ASIEDU, JSC;

[1] My Lords, the Appellant/Applicant herein, the Commissioner General of the Ghana Revenue Authority (GRA), assessed the tax liability of the Respondent, Perseus Mining Ghana Limited, on the 6 January 2020, and issued a final tax audit report with a tax liability of $8,725,387.47.

[2] The Respondent objected to the assessment and paid the statutory minimum tax required to be paid upon objection to an assessment in the sum of GH₵13, 385,180.41 which was the cedi equivalent of $2,501,902.88

[3] After considering the objection filed by the Respondent herein, a final decision on the objection was issued by the Appellant/Applicant on the 15 March 2021 wherein the tax liability was revised to the sum of $7,509,110.29.

[4] My Lords, dissatisfied with the objection decision, the Respondent filed an appeal with the High Court which, after hearing the said appeal, dismissed same on the 8th February 2022, and, entered judgment in favour of the Appellant/Applicant.

[5] A further ap…