The Ghana Revenue Authority (GRA) is challenging a GH¢79.65 million judgment debt awarded to Servestar Minwax (WA) Limited, arguing that the amount being pursued should first undergo an independent reconciliation before any payment is made from its Tax Refund Account.
The dispute, which dates back to 2009, reportedly began over an alleged overpayment of import duties of less than GH¢1 million.
Although Servestar Minwax subsequently secured judgment against the GRA, the Authority says the amount being enforced through garnishee proceedings has since ballooned 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 release the amount from the GRA Tax Refund Account to Servestar Minwax and its director, Henry Manly-Spain.
The GRA has since applied to have the Garnishee Order Absolute set aside and has also filed a Notice of Appeal against the ruling.
A key development in the dispute is the court’s decision on August 20 to allow a forensic reconciliation of the judgment sum, paving the way for an independent auditor to examine the amount being claimed.
“GRA’s application includes a request for a forensic reconciliation of the judgment sum as asserted by the plaintiff to ensure that the correct amount is reflected,” the Authority said.
The GRA maintains that its own reconciliation shows a significantly lower amount as legitimately owed to the company.
In a further twist, the Authority said Mr Manly-Spain himself has disputed the GH¢79.65 million figure.
According to the GRA, documents submitted to his solicitor indicate that his legitimate claim for overpaid duties and the value of containers sold since 2009 is considerably below the amount awarded by the court.
“His legitimate claim against GRA for overpaid duties and the value of containers sold, dating back to 2009, is significantly less than the GH¢79.7 million awarded by the Court,” the Authority said.
The GRA said Mr Manly-Spain’s position has been formally placed before the court as part of the proceedings seeking to set aside the garnishee order and establish the accurate amount of the judgment debt.
Beyond disputing the amount, the Authority is also challenging the attachment of its Tax Refund Account at the Bank of Ghana.
It argues that the account, established under Section 69 of the Revenue Administration Act, 2016 (Act 915), is legally protected and specifically intended for legitimate tax refunds.
“GRA maintains that the Refund Account held at the Bank of Ghana…is a statutorily protected account designated for the payment of legitimate refunds to taxpayers who have overpaid and cannot be subjected to attachment in the manner directed,” it said.
The Authority said its initial application for a stay of execution was unsuccessful but intends to renew the application before the Court of Appeal at the start of the new legal year.
Meanwhile, the Commissioner-General has directed an internal audit into the reconciliation and litigation processes surrounding the case to determine whether any lapses occurred and strengthen the Authority’s internal controls.
The GRA said the measures are intended to safeguard public funds while ensuring that lawful court decisions are respected.
“The Authority reiterates its commitment to abide by the rule of law and adherence to the lawful decisions of the honourable court in the interest of justice; while at the same time it exercises the legitimate responsibility to defend the interest of the state,” it said.
Also read:
Read the full statement below:
