The Ghana Revenue Authority (GRA) has filed a Notice of Appeal challenging a High Court ruling that directed the payment of GH¢79.65 million to Servestar Minwax (WA) Limited in a long-running judgment debt dispute.
The appeal follows a Garnishee Order Absolute issued by the High Court Commercial Division 3 on July 22, 2026, directing the Bank of Ghana (BoG) to release GH¢79.65 million from the GRA’s Tax Refund Account to Servestar Minwax and its Director, Henry Manly-Spain.
According to the GRA, its legal team has appealed the entire High Court decision and is also seeking to have the Garnishee Order Absolute set aside.
GRA Challenges GH¢79.65 Million Judgment Debt
The revenue authority said it considers the judgment amount excessive and has requested a forensic reconciliation to establish the precise sum legitimately owed to Servestar Minwax.
In a statement issued on Tuesday, the GRA confirmed that its lawyers had formally filed the Notice of Appeal against the High Court ruling.
The authority explained that an earlier application for a stay of execution was rejected by the High Court. It said a fresh application for a stay would be filed at the Court of Appeal at the beginning of the new legal year.
The GRA has also applied to set aside the Garnishee Order Absolute, citing what it described as significant discrepancies in the certified judgment debt.
Dispute Dates Back to 2009 Import Duty Overpayment
The legal dispute reportedly stems from an import duty overpayment of less than GH¢1 million in 2009.
Servestar Minwax subsequently initiated legal proceedings against the GRA and secured a judgment in its favour.
However, the GRA says the major issue in the current dispute is the substantial difference between the amount it acknowledged following its own reconciliation and the GH¢79.65 million awarded by the court.
The authority attributed the difference largely to the application of 35 percent daily compound interest, which significantly increased the original amount.
The GRA has therefore requested an independent forensic reconciliation of the judgment sum claimed by Servestar Minwax to determine the amount that should legitimately be paid.
GRA Challenges Attachment of Tax Refund Account
The Ghana Revenue Authority has also challenged the decision to attach its Tax Refund Account held at the Bank of Ghana.
The GRA maintains that the account was created specifically to facilitate the payment of legitimate tax refunds to taxpayers who have overpaid their taxes.
According to the authority, the account enjoys statutory protection under Section 69 of the Revenue Administration Act, 2016 (Act 915) and should not be subjected to attachment in the manner ordered by the High Court.
The GRA argues that using funds designated for legitimate taxpayer refunds to settle an unvalidated judgment debt could affect the statutory purpose of the account.
Independent Auditor to Review Judgment Sum
The GRA disclosed that on August 20, 2026, the High Court granted its request for an independent auditor to examine and reconcile the judgment amount being claimed by Servestar Minwax.
The authority said the independent review is expected to help establish the accurate financial obligation arising from the case.
In addition, the Commissioner-General of the GRA has ordered an internal audit of the reconciliation and litigation processes associated with the dispute.
The internal review is intended to identify any possible administrative lapses and strengthen the authority’s internal controls.
Henry Manly-Spain Petitions Against Payment
The GRA also disclosed that it had received a petition from Henry Manly-Spain requesting that the authority should not release the judgment amount.
The authority said the petition has been presented to the court as part of its application seeking to set aside the Garnishee Order Absolute.
The GRA further commended Manly-Spain for publicly indicating that the amount he believes is legitimately owed to him is significantly lower than the GH¢79.65 million awarded by the court.
The authority said his claim relates to overpaid import duties and the value of containers sold, with the underlying transactions dating back to 2009.
GRA Vows to Protect Public Revenue
The GRA said it remains committed to protecting the financial interests of the state while respecting the rule of law and lawful court decisions.
The authority stressed that it would not allow what it considers to be unvalidated judgment debts to be paid from funds meant for tax refunds and other legitimate public purposes.
The ongoing case between the GRA and Servestar Minwax is therefore expected to be closely watched as the authority pursues its appeal and seeks further clarification of the judgment debt through forensic and independent financial reviews.
Source: newsthemegh.com