Interpretation of tax statutes in Ghana case law.

It is significant to state that, of particular importance to the distinction is that, where the Petroleum Agreement intended the Subcontractor to be liable with any tax liability, it was emphatic on same. The court cannot, be seen to be on a presumptions voyage nor purport to impose a tax liability by implication on the Appellant (a Sub-contractor) when the same has neither been expressly spelt out in the Petroleum Agreement nor the Sub-Contract Agreement between the Appellant and ENI.

MAERSK DRILLSHIP IV SINGAPORE PTE LTD. (SUING PER ITS LAWFUL ATTORNEY, JORGEN SCHAFFER) VS. THE COMMISSIONER GENERAL GHANA REVENUE AUTHORITY CIVIL APPEAL NO. J4/59/2024 [2025] SLR (SC) 7 · Supreme Court · 2025 · TANKO AMADU JSC

In the words of the late Rowlatt J. whose outstanding knowledge of this subject was coupled with a happy consciences of phrase, “in a taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to tax. Nothing is to be read in, nothing is to be implied.

MAERSK DRILLSHIP IV SINGAPORE PTE LTD. (SUING PER ITS LAWFUL ATTORNEY, JORGEN SCHAFFER) VS. THE COMMISSIONER GENERAL GHANA REVENUE AUTHORITY CIVIL APPEAL NO. J4/59/2024 [2025] SLR (SC) 7 · Supreme Court · 2025 · TANKO AMADU JSC