[2023]DLHC17773July 20, 2023High Court

UNILEVER GHANA LIMITED vs. THE COMMISSIONER GENERAL, GHANA REVENUE AUTHORITY (GRA)

Unilever Ghana Limited (Appellant) filed an appeal against a tax assessment made by the Commissioner General of the Ghana Revenue Authority (Respondent) dated 21 February 2019, relating to tax liabilities on Transfer Pricing Returns and Financial Statements for 2012-2016, amounting to GH¢6,236,200.00. The Appellant objected to the assessment, but the objection was disallowed by the Respondent. Dissatisfied, the Appellant appealed to the High Court.

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JUDGMENT On 17th March 2021, Unilever Ghana Limited (hereinafter called the Appellant) filed Appeal against the Commissioner-General, Ghana Revenue Authority (hereinafter called the Respondent) before this Court. The Appeal is in respect of Tax Assessment made by the Respondent against the Appellant on 21st February, 2019 which the Appellant has attached as exhibit 5 to the Notice of Appeal. Per exhibit 5, the Appellant tax liability per it Transfer Pricing Returns and Financial Statements submitted for 2012-2016 years of Assessment was Six Million, Two Hundred and Thirty-Six Thousand, Two Hundred Cedis (GH¢6,236,200.00). The Appellant was required to pay the amount stated above within fourteen days from 21st February, 2019. The Appellant objected to the assessment by the Respondent in a letter dated 20th May, 2019 which the Appellant attached as exhibit 6 to the Notice of Appeal. The Respondent opinion on the objection is dated 19th September, 2019. It has been atta....