GRA Targets Law Firm with Tax Audit One Week After Supreme Court Suit Over Exemption Laws

The Ghana Revenue Authority (GRA) has served a tax audit notice to the law firm of legal practitioner Jonathan A. Alua, barely a week after he mounted a constitutional challenge against the tax authority and the Attorney-General in the Supreme Court.

In a formal letter dated September 9, 2026, the GRA notified Alua’s firm that it had been selected for a comprehensive tax audit covering the 2023, 2024, and 2025 financial years.

The swift timing of the audit notice has drawn intense public scrutiny, coming directly on the heels of Alua’s suit contesting the statutory powers of the GRA Commissioner-General regarding passenger baggage duty exemptions.

Constitutional Challenge Over Statutory Tax Powers

In his suit before the apex court, Alua is seeking a declaration that Regulation 18(2)(b) of the Exemptions Regulations, 2025 (L.I. 2514) is unconstitutional.

The lawsuit focuses on provisions that empower the Commissioner-General to waive or adjust customs duties and passenger baggage taxes. Alua argues that granting an administrative head unilateral discretion to waive or vary taxes without prior parliamentary approval violates core constitutional principles governing national taxation.

While the Supreme Court has yet to set a date to hear the matter, the lawsuit raises significant questions regarding executive discretion, legislative oversight, and administrative authority in tax policy.

Authority Denies Wrongdoing as Legal Team Reacts

Addressing the audit notice, the GRA maintained that the exercise falls strictly within its statutory enforcement mandate and does not signify non-compliance.

“This is to inform you that your company has been selected for audit under the provisions of the Tax Laws for the periods 2023-2025. We would like to assure you that this exercise does not suggest you have done anything wrong,” the GRA stated in its letter to the firm.

Reacting publicly to the audit notice, Alua expressed surprise at the sudden timing of the administrative review, sharing the notice on social media accompanied by a laughing emoji.

Although the GRA has not linked the tax audit to the pending Supreme Court case, the simultaneous development adds a high-stakes layer to the ongoing legal battle.