The development follows a Garnishee Order issued by the High Court (Commercial Division 3) on July 22, 2026, directing the Bank of Ghana to release GH¢79,651,132 from the GRA Tax Refund Account to Servestar Minwax and its Director, Henry Manly-Spain.
The GRA argues that the Tax Refund Account cannot lawfully be attached in the manner directed by the Court.
The Authority cited Section 69 of the Revenue Administration Act, 2016 (Act 915), saying the account held at the Bank of Ghana is statutorily protected and specifically designated for paying legitimate tax refunds to taxpayers who have overpaid.
“GRA maintains that the Refund Account held at the Bank of Ghana, pursuant to Section 69 of the Revenue Administration Act, 2016 [Act 915], 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.”
The GRA said it has filed a Notice of Appeal against the entire High Court ruling.
It further disclosed that its application for a stay of execution was dismissed by the High Court, but it intends to renew the application at the Court of Appeal at the commencement of the legal year.
The Authority has also applied to set aside the Garnishee Order Absolute and requested a forensic reconciliation of the judgment sum.
The Court granted the request on August 20, 2026, allowing an independent auditor to review and reconcile the amount claimed by the plaintiff.
The GRA said it believes the amount being claimed is excessive and has consequently initiated further internal reviews.
“The Commissioner-General has mandated an internal audit of the entire reconciliation and litigation process concerning this case to identify any lapses and bolster controls.”
The GRA also confirmed receiving a petition from Henry Manly-Spain asking the Authority to refrain from disbursing the judgment amount.
The Authority commended Mr Manly-Spain for what it described as “exceptional honesty, integrity, and patriotism.”
According to the GRA, Mr Manly-Spain has publicly indicated that, based on documents submitted to his solicitor, his legitimate claim relating to overpaid duties and the value of containers sold dating back to 2009 was significantly lower than the amount awarded by the Court.
The GRA assured taxpayers and the business community that it would take steps to prevent unvalidated judgment debts from being paid from public revenue.
“GRA will not permit unvalidated judgment debts to be paid from tax revenue,” the Authority stated.
It reaffirmed its commitment to the rule of law, saying it would comply with lawful court decisions while taking all necessary legal steps to protect the financial interests of the State.
