The Ghana Revenue Authority (GRA) has served an audit notice on the law firm of legal practitioner Jonathan A. Alua, days after he sued the Attorney-General and the GRA’s Commissioner-General over the Authority’s power to determine passenger baggage exemptions from customs duties and taxes.
A letter dated September 9, 2026 and addressed to the Managing Director of Astra Legal & Consultancy Services, sighted by 3news, indicates that the law firm has been selected for a tax audit covering the 2023 to 2025 tax years.
The audit, according to the letter, will cover Corporate Income Tax (CIT), Withholding Tax (WHT), PAYE and VAT/NHIL/GETFund.
The GRA has assigned a three-member team to conduct the exercise.
The Authority, however, stressed in the letter that the audit “does not suggest you have done anything wrong,” and said the exercise was being conducted under the provisions of the tax laws.
The notice comes shortly after Mr 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. Mr Alua argues that the exercise of that discretion 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, among other reliefs, 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 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.
