Ghana Cross-Border Tax

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

Tax year: 2026. Law: Income Tax Act, 2015 (Act 896) as amended. The GRA table was last edited in 2022; each rate was read there, and later statute changes are listed under Sources.

Who this applies to

Residents paying non-residents, non-residents earning from Ghana, and residents with foreign income. Residence tests for individuals are in ghana-pit, for companies in gh-corporate-income-tax. A partnership is resident if any partner lived in Ghana during the year. A trust is resident if established in Ghana, if a trustee is resident, or if a resident directs senior decisions (Act 896 s.101).

Rates, bands and thresholds

Payment to a non-resident	Rate	Conditions	Tax year	Official URL
Dividends	8%	Final	2026	https://gra.gov.gh/domestic-tax/tax-types/withholding-tax/
Interest	8%	Excluding individuals	2026	same
Management and technical service fees	20%	Final unless through a Ghanaian permanent establishment	2026	same
Goods, works or any services	20%	Contract with a non-resident	2026	same
Royalties, natural resource payments, rents	15%	Final	2026	same
Telecommunications and transport income	15%	Final	2026	same
Petroleum subcontractors	15%	Final	2026	same
Repatriated branch after-tax profits	8%	Branch	2026	same
General insurance premiums	5%	Final	2026	same
Asset or liability realisation	10% of consideration	Resident payer not an individual (s.116A)	2026	https://gra.gov.gh/wp-content/uploads/2023/04/INCOME-TAX-AMENDMENT-ACT-2023-ACT-1094.pdf

Payment to a resident	Rate	Conditions	Tax year	Official URL
Dividends	8%	Final	2026	https://gra.gov.gh/domestic-tax/tax-types/withholding-tax/
Interest	8%	Not to individuals or resident financial institutions	2026	same
Rent, residential	8%		2026	same
Rent, non-residential	15%		2026	same
Invigilators, examiners, part-time teachers or lecturers, endorsement fees	10%	Individuals	2026	same
Directors, managers, board members, trustees	20%	Resident individuals	2026	same
Commission to insurance, sales, canvassing and lotto agents	10%	Individuals	2026	same
Services	7.5%	By an entity, above GHS 2,000 a year; general services by an individual	2026	same
Goods	3%	Above GHS 2,000 a year	2026	same
Works	5%	Above GHS 2,000 a year	2026	same
Unprocessed precious minerals	3%		2026	same
Petroleum subcontractors	7.5%	Final	2026	same
Royalty, natural resource payments	15%		2026	same
Asset or liability realisation	3% of consideration	Resident payer not an individual (s.116A)	2026	https://gra.gov.gh/wp-content/uploads/2023/04/INCOME-TAX-AMENDMENT-ACT-2023-ACT-1094.pdf
Lottery winnings	10% of gross winnings	End of each game	2026	same

The base

Withhold on the gross payment. Payments by an individual outside a business, employee pay, interest to a resident financial institution and exempt amounts are outside investment-return withholding (GRA).

Final payments are not taxed again: dividends by a resident company, rent by a resident individual, rent outside a letting business, payments to non-residents other than through a Ghanaian permanent establishment, petroleum subcontractor payments, and examination and endorsement fees. For anything else the payee claims a credit.

Treaties: GRA lists Belgium, Czech Republic, Denmark, France, Germany, Italy, Mauritius, Morocco, Netherlands, Qatar, Singapore, South Africa, Switzerland and the United Kingdom (GRA). Read the treaty itself for the rate. A treaty rate needs the recipient to qualify.

Foreign tax credit: resident other than a partnership, separately by income source, capped at the average Ghanaian rate on that income (s.112).

Deadlines and filing

Obligation	Date	Official URL
Notice of a contract with a non-resident	Within 30 days of the contract date	https://gra.gov.gh/domestic-tax/tax-types/withholding-tax/
Withholding statement and payment	Within 15 days after the month end	same
Withholding certificate	To the payee	same

Monthly return:

1. Log in at www.etax.gra.gov.gh (ITAS).
2. Open the Withholding Tax return, DT 110, for the month.
3. Upload the DT 110 items file, giving each payee, payment and rate.
4. Submit, keep the acknowledgement, pay through Ghana.gov.
5. Give each payee a certificate. Taxpayers attach them to annual returns.

Penalties and interest

A withholding agent who fails to withhold is liable for the tax and may recover it from the payee (GRA). Late return: GHS 500 plus GHS 10 a day. Late payment: 125% of the Bank of Ghana policy rate, compounded monthly (Act 915).

Cross-border points

• Imported services and digital services also carry VAT: see ghana-vat.
• Related-party pricing: see gh-transfer-pricing.
• A person who stops being resident is treated as realising assets at market value on that date; a person who becomes resident takes market value as cost (Act 896 s.102(3) to (5), not for domestic assets, s.102(6)).

Two worked examples that recompute

Example 1: service fee abroad. A Ghana company owes a UK consultant GHS 100,000 under no treaty relief claim. It withholds 20%, GHS 20,000, pays GHS 80,000, and remits by the 15th of the next month.

name: Non-resident service fee
inputs:
  fee: 100000
steps:
  - wht: fee * 0.20
  - net: fee - wht
expected:
  wht: 20000.00
  net: 80000.00

Example 2: branch or subsidiary? After-tax profit of GHS 750,000 from GHS 1,000,000 at 25%. A branch pays 8% on repatriated profit, a subsidiary pays 8% on the dividend. On full distribution each costs GHS 60,000, so withholding does not decide it; retained profit does, as a branch pays only on what it repatriates and a subsidiary only on what it distributes.

name: Branch against subsidiary
inputs:
  profit: 1000000
steps:
  - after_tax: profit * 0.75
  - branch: after_tax * 0.08
  - subsidiary: after_tax * 0.08
  - gap: branch - subsidiary
expected:
  branch: 60000.00
  gap: 0.00

Ask the client first

1. Payer and payee residence.
2. Type of payment and contract date.
3. Treaty country, and proof the recipient qualifies.
4. Any Ghanaian permanent establishment.
5. Whether the payer is an individual outside a business.

Sources

Source	URL	Read on
GRA, Withholding Tax page (rates table, last edited 2022), page read in full	https://gra.gov.gh/domestic-tax/tax-types/withholding-tax/	2026-11-01
Income Tax (Amendment) Act, 2023 (Act 1094), whole act	https://gra.gov.gh/wp-content/uploads/2023/04/INCOME-TAX-AMENDMENT-ACT-2023-ACT-1094.pdf	2026-11-01
Income Tax Act, 2015 (Act 896), OCR of scan; ss 33, 101, 102, 112, 121, 124, 125 read	https://gra.gov.gh/wp-content/uploads/2020/09/INCOME-TAX-ACT-2015-ACT-896.pdf	2026-11-01
Revenue Administration Act, 2016 (Act 915); ss 27 to 30, 46, 47, 70 to 73 read	https://gra.gov.gh/wp-content/uploads/2023/01/Revenue-Administration-Act-2016-.pdf	2026-11-01
GRA, Double Taxation Agreements page (country list), page read in full	https://gra.gov.gh/double-taxation-agreements/	2026-11-01
GRA, ITAS FAQs, page read in full	https://gra.gov.gh/itas-faqs/	2026-11-01

Not yet confirmed: (1) Treaty rates and in-force status: GRA page lists countries only, under a heading on status; treaties were not read. (2) GRA withholding table dates from 2022; changes in Acts 1066, 1071 and any later act were not read, and the Act 1178 notice mentions only individual bands and MTS. The Finance Ministry 2025 report says Act 1129 abolished a 1.5% withholding on unprocessed gold by small-scale miners; Act 1129 itself was not read, and the 3% row may be affected for that gold. (3) The DT 110 screen layout on ETAX. (4) The GRA form list shows an older Excel DT 110; the upload format may differ on ETAX.