The Ghana Revenue Authority (GRA) has challenged the GH¢79.65 million judgment debt awarded to Servestar Minwax (WA) Limited, insisting that the amount significantly exceeds the company’s legitimate claim arising from an import duty overpayment dating back to 2009.
The GRA’s position follows a Garnishee Order issued by the High Court (Commercial Division 3) on July 22, 2026, directing the Bank of Ghana to disburse GH¢79,651,132 from the GRA Tax Refund Account to Servestar Minwax and its Director, Henry Manly-Spain.
According to the GRA, the dispute originated from an alleged overpayment of import duties amounting to less than GH¢1 million in 2009.
The company subsequently sued the Authority, resulting in a judgment in its favour. However, the GRA says the central issue now concerns the difference between the amount it reconciled as owing and the GH¢79.65 million liability awarded by the Court.
The Authority said the judgment sum includes what it described as 35% daily compound interest, which has substantially increased the amount payable through the garnishee proceedings.
GRA challenges attachment of refund account
The GRA has also disputed the attachment of its Tax Refund Account at the Bank of Ghana.
It argues that the account is statutorily protected under Section 69 of the Revenue Administration Act, 2016 (Act 915), and is specifically designated for the payment of legitimate tax refunds to taxpayers who have overpaid.
The Authority maintains that the account cannot be subjected to attachment in the manner directed by the Garnishee Order.
Appeal and forensic audit
In response to the judgment, the GRA said it has filed a Notice of Appeal against the entirety of the High Court’s ruling.
It also disclosed that an earlier application for a stay of execution was denied by the High Court, but a renewed application is expected to be filed at the Court of Appeal at the commencement of the new legal year.
The Authority has further applied to set aside the Garnishee Order Absolute, citing what it describes as material discrepancies in the certified judgment debt.
As part of that application, the GRA requested a forensic reconciliation of the judgment sum. The Court, according to the Authority, granted the request on August 20, 2026, allowing for the appointment of an independent auditor to review and reconcile the amount being claimed by Servestar Minwax.
The GRA said it believes the claimed amount is excessive.
Internal audit ordered
Beyond the ongoing court processes, the Commissioner-General has ordered an internal audit of the entire reconciliation and litigation process surrounding the case.
The audit is intended to identify any lapses and strengthen the Authority’s internal controls, according to the statement.
Servestar director rejects GH¢79.65m award
The GRA also disclosed that it has received a petition from Henry Manly-Spain asking the Authority not to disburse the judgment amount.
According to the GRA, Mr. Manly-Spain has publicly indicated that, based on documents submitted to his solicitor, his legitimate claim against the Authority for overpaid duties and the value of containers sold since 2009 is significantly less than the GH¢79.7 million awarded by the Court.
The GRA said the petition has been formally recorded before the Court as part of its application to set aside the Garnishee Order Absolute and reconcile the judgment sum.
GRA assures taxpayers
The Authority has commended Mr. Manly-Spain for what it described as exceptional honesty, integrity and patriotism in publicly questioning the size of the award.
The GRA further assured taxpayers and the business community that it would not permit what it described as unvalidated judgment debts to be paid from tax revenue.
It nevertheless stressed that it remains committed to respecting lawful court decisions while exercising what it described as its legitimate responsibility to protect the interests of the State.
The statement was issued by the GRA’s Communication and Public Affairs Department on September 15, 2026.
