GRA Introduces 20% Upfront VAT Payment for Unregistered Importers

The Ghana Revenue Authority (GRA) has outlined new measures under the amended Value Added Tax (VAT) Act, 2023 (Act 1151), introducing an upfront payment regime for certain importers beginning January 2026.

According to the guidelines, importers of taxable goods with an import VAT base exceeding GH¢750,000 who are required to register for VAT but remain unregistered will be mandated to make an upfront payment equivalent to 20% of the customs value of the taxable goods at the point of importation. This payment will be made in addition to applicable customs duties, import VAT and other statutory levies.

The Authority explained that the upfront payment applies to taxable goods imported for domestic consumption, including uncustomed goods that are forfeited and later auctioned. However, affected importers will be eligible to recover the upfront payment once they subsequently register for VAT and duly file their VAT returns, in line with provisions of the Act.

The GRA further detailed the mechanism for identifying importers liable for the upfront payment. Under the process, an importer submits a Bill of Entry (BOE) declaration to clear goods, after which the Integrated Customs Management System (ICUMS) assesses whether the import VAT base exceeds the GH¢750,000 threshold. Where this condition is met, ICUMS verifies the importer’s VAT registration status.

Importers who are already registered for VAT will not be charged the upfront payment. Conversely, unregistered importers will be required to pay the 20% upfront amount, which will appear on the BOE as a new tax line labelled “upfront payment by VAT unregistered importer” under Tax Code 101.

The guidelines also allow unregistered importers to apply for a waiver if they can demonstrate that the imports are not in furtherance of taxable economic activity. Applications for waivers are to be submitted through the ICUMS single window portal. Where approved, the BOE will be amended to remove the upfront payment; where rejected, the importer must proceed to make the payment.

Certain categories of imports are also exempt from the upfront payment requirement. These include exempt imports listed under the First Schedule of the VAT Act, as well as goods classified as exempt under the Third Schedule of the Customs Act, 2015 (Act 905), and the Exemptions Act, 2022 (Act 1083). Items imported for personal use and goods not intended for domestic consumption—such as temporary imports, free zone imports, transit goods, transhipments, warehoused cargo and other suspended cargo—are also excluded.

Relief imports are similarly exempt. These cover imports by persons listed in the Third Schedule of the Act, including government institutions and agencies, diplomatic missions, and other privileged or exempt entities. Additionally, taxable goods with an import VAT base below the GH¢750,000 threshold do not attract the upfront payment.

On recovery of the upfront payment, the GRA noted that an importer may apply to the Commissioner-General upon meeting specific conditions. These include providing evidence of the upfront payment, being registered for VAT where applicable, and filing all relevant VAT returns.

Applications for recovery can be submitted electronically via the “Recovery of Upfront Payment” form on the taxpayer portal or lodged physically at the importer’s assigned Taxpayer Service Centre.