Tax regime more data-driven, enforcement-focused                                        

By Joshua AMLANU

The country’s tax system is becoming “more data-driven, more enforcement-oriented and more ambitious than at any point in the modern fiscal history”, law firm Bentsi-Enchill, Letsa & Ankomah (BELA) has said.

This comes amid government’s efforts to intensify domestic revenue mobilisation ahead of the International Monetary Fund programme’s expected conclusion in 2026.

In its Tax Outlook 2026 report, the firm said Ghana Revenue Authority’s expanding digital capabilities – combined with sweeping reforms to value-added tax administration and transfer pricing enforcement – are fundamentally changing the compliance environment for businesses operating in the country.

The report comes as government seeks to sustain fiscal consolidation gains made under the IMF-supported US$3billion Extended Credit Facility programme secured in 2023, following a severe debt and balance-of-payments crisis.

“Discrepancies will be detected earlier, scrutiny will be more targetted and tolerance for informal tax positions will narrow considerably,” BELA said in the report. It added that the era in which tax risks could be managed through periodic engagement with auditors is giving way to “continuous, data-enabled oversight”.

A central component of the new enforcement strategy is operationalisation of the Integrated Tax Administration System (ITAS), launched on April 1, 2026. The platform automates taxpayer registration, filing, payment, assessment and audit functions while enabling GRA to cross-reference taxpayer information with data from banks, the Lands Commission, Office of the Registrar of Companies and immigration authorities.

According to BELA, the system significantly improves GRA’s ability to identify inconsistencies across taxpayer records and target audits more precisely.

The report said the Fiscal Electronic Devices (FEDs) nationwide rollout also marks a structural shift in VAT enforcement. The devices transmit transaction data from point-of-sale systems directly to GRA in real time, reducing opportunities for under-reporting sales and creating what the report described as a “continuous audit trail”.

“For businesses within the FED regime, the era in which VAT compliance risk was concentrated in the annual audit cycle is effectively over,” the report stated.

The changes form part of a broader revenue mobilisation drive after Ghana’s tax-to-GDP ratio fell to about 13.8 percent in 2022, below the sub-Saharan African average and far below levels considered necessary to sustainably finance public services.

While total tax revenue rose to about GH¢153.5billion in 2025 from GH¢113.4billion in 2024, BELA cautioned that part of the increase reflected inflation-driven expansion in nominal tax values rather than a durable broadening of the tax base.

The report said Ghana’s fiscal strategy has shifted tax policy from the “periphery to the centre of economic management” after the country lost access to international capital markets and undertook one of Africa’s largest sovereign debt restructurings.

Authorities have since introduced sweeping legislative reforms including a new VAT regime that took effect in January 2026. The reforms abolished the COVID-19 levy, restructured the VAT calculation framework and introduced deductibility for certain levies previously treated as embedded business costs.

The report also highlighted abolition of the VAT Flat Rate Scheme, requiring many retailers and wholesalers to migrate fully onto the standard VAT system with stricter invoicing and reporting obligations.

Sectors expected to face heightened enforcement scrutiny include mining, oil and gas, telecommunications, financial services, real estate and import-dependent businesses. BELA said GRA’s Transfer Pricing Unit is also intensifying audits using Country-by-Country Reporting data and information exchange agreements to identify multinational companies reporting unusually low profits in Ghana relative to their global operations.

The report warned that the tax environment could become even more aggressive if fiscal pressures re-emerge after the IMF programme ends, particularly if revenue performance weakens or external shocks affect commodity prices and exchange rate stability.

“In this scenario, the tax system becomes an instrument of short-term revenue extraction rather than long-term economic development,” the report said.

Nonetheless, BELA said a more stable outcome remains possible if macroeconomic gains hold and reforms are implemented consistently. Inflation declined sharply through 2025 – falling to 5.4 percent by December from 23.8 percent at start of the year, while the Bank of Ghana cut its benchmark policy rate by 1,000 basis points to 18 percent by end-2025.

The firm said businesses that invest early in tax governance systems, documentation and compliance infrastructure will be better positioned to navigate the evolving enforcement environment and reduce exposure to penalties, disputes and reputational risks.

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