MAERSK DRILLSHIP vs THE COMMISSIONER-GENERAL GHANA REVENUE AUTHORITY

JUDGMENT BARTELS-KODWO, JA: INTRODUCTION This is an appeal against the ruling of the High Court, (Commercial Division) Accra dated 19th October 2022 which decision upheld in part, an appeal brought by Maersk Drillship IV Singapore (hereinafter referred to as "the Appellant_")against the Final Objection Decision of the Commissioner-General of the· Ghana Revenue Authority (hereinafter referred to as "the Respondent) dated 27th September 2021. The dispute between the parties concerns the interpretation and application of Articles 12(1) and (3) as well as Article 26 of the Offshore Cape Three Points Petroleum Agreement, Sections 27 and 39(3) of the Petroleum Income Tax Act, 1987 (PNDC Law 188), the Internal Revenue Act, 2000 (Act 592) and the Income Tax Act 2015 (Act 896). The instant appeal requires that this Honourable Court properly construe and apply the above provisions. This is because the central contention of the Appellant in this appeal is that on a true and proper construct....