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The Ghana Revenue Authority (GRA) has challenged a GH¢79.65 million judgment debt awarded to Servestar Minwax (WA) Limited, arguing that the amount should be independently reconciled before any payment is made from its Tax Refund Account.
The dispute dates back to 2009 and centres on an alleged overpayment of import duties of less than GH¢1 million, according to the GRA.
Servestar Minwax subsequently sued the Authority and secured judgment in its favour. However, the GRA says the amount being pursued through garnishee proceedings has since risen to GH¢79,651,132, including what it describes as 35% daily compound interest.
On July 22, 2026, the High Court (Commercial Division 3) issued a Garnishee Order directing the Bank of Ghana to pay the amount from the GRA’s Tax Refund Account to Servestar Minwax and its director, Henry Manly-Spain.
The GRA has applied to set aside the Garnishee Order Absolute and has also filed a Notice of Appeal against the entire ruling.
As part of the legal proceedings, the Authority requested a forensic reconciliation of the judgment sum. The request was granted by the court on August 20, allowing an independent auditor to examine the amount being claimed.
The GRA maintains that the GH¢79.65 million figure is substantially higher than the amount it had previously reconciled as legitimately owed to the company.
In an unusual development, the Authority said Henry Manly-Spain himself has also disputed the amount awarded by the court.
According to the GRA, Mr Manly-Spain has indicated, based on documents submitted to his solicitor, that his legitimate claim for overpaid duties and the value of containers sold since 2009 is significantly lower than the judgment sum.
The Authority said Mr Manly-Spain’s position has been formally placed before the court as part of proceedings to set aside the garnishee order and reconcile the judgment debt.
GRA Challenges Attachment of Tax Refund Account
The Authority is also contesting the attachment of its Tax Refund Account, arguing that the account is statutorily protected and specifically designated for legitimate taxpayer refunds.
The GRA said the account, maintained at the Bank of Ghana under Section 69 of the Revenue Administration Act, 2016 (Act 915), cannot be attached in the manner directed by the court.
The Authority further disclosed that its initial application for a stay of execution was denied, but it intends to renew the application before the Court of Appeal at the commencement of the legal year.
Meanwhile, the Commissioner-General has ordered an internal audit into the reconciliation and litigation processes surrounding the case to identify any lapses and strengthen internal controls.
The GRA said the measures are intended to protect public funds while ensuring compliance with lawful court decisions.
The Authority reiterated its commitment to respecting the rule of law while defending the interests of the state in the ongoing proceedings.