# Ghana's tax rules for Tabula's billing

What the public law requires of Tutelora charging customers in Ghana, read on 6 November 2026, and what Tabula does about it. This is a reading of the published
Acts and the Ghana Revenue Authority's (GRA) pages. Check the sources again before billing is switched on, because these rules changed on 1 January 2026.

## What Tutelora's subscriptions are

**Taxable, at an effective 20%.** Educational institutions' own fees are exempt, but a software subscription sold *to* a school isn't their supply. The First Schedule
exempts "a supply of education services" and has no entry for software, which the Act treats as taxable (s.5(2)(h)), and a supply is exempt only if the Schedule
lists it (s.35). So the school is charged the tax. Because its own supplies are exempt, it generally can't reclaim it, so **the tax is a real cost to the school, and
the price it sees should say so.**

## The rules

| Rule | What the law says | Source |
|---|---|---|
| **Registration** | Services have **no turnover threshold**: register "within thirty days after engaging in the taxable activity". The GHS 750,000 threshold is for goods only | VAT Act 2025 (Act 1151), s.6 |
| **Not registering** | A penalty of not less than three times the tax on taxable supplies, from when registration was due until the application | Act 1151, s.16 |
| **The charge** | VAT 15%, NHIL 2.5% and GETFund 2.5%, each on the value of the supply. GHS 1,000 becomes GHS 1,200. The 1% COVID levy is gone, and so is the old cascade | Act 1151, s.3; [GRA, VAT](https://gra.gov.gh/domestic-tax/tax-types/vat/) |
| **The invoice** | Separate lines for NHIL, GETFund and VAT, with the total of them mandatory. Prices are stated excluding levies and VAT | [GRA, VAT](https://gra.gov.gh/domestic-tax/tax-types/vat/) |
| **E-VAT** | A tax invoice must be issued "through a Certified Invoicing System" integrated with the Commissioner-General's | Act 1151, s.43(2) |
| **How to get E-VAT** | Free software from the GRA, or a version integrated with your own system. Write to your Taxpayer Service Centre to request it | [GRA, E-VAT](https://gra.gov.gh/e-services/e-vat/) |
| **How integration works** | Each invoice goes to the GRA by API, which returns a signature, QR code, invoice number and timestamp to print on it. Onboarding is in batches, with about four weeks of testing | [Fonoa, July 2026](https://www.fonoa.com/resources/blog/ghana-e-vat-e-invoicing-2026), a secondary source |
| **When tax falls due on a subscription** | Each period is a separate supply, at the earlier of payment due, payment received or the invoice | Act 1151, s.39(5) |
| **Returns** | Monthly, by the last working day of the next month, with any payment due the same day, even if nothing is payable | Act 1151, ss.59(5), 60(1) |
| **Withholding tax** | A resident payer other than an individual withholds **7.5%** on services over GHS 2,000 per contract, due to the GRA within 15 days of the month's end. It's a credit against Tutelora's income tax, not a final tax | [PwC, reviewed 27 Oct 2026](https://taxsummaries.pwc.com/Ghana/Corporate/Withholding-taxes); [TaxLawGH](https://www.taxlawgh.com/ghana-withholding-tax) citing Act 896 |
| **Withholding VAT** | Agents appointed by the Commissioner-General withhold **7%** of the taxable value and issue a certificate, which is proof of advance payment | Act 1151, s.56; [GRA, VAT Withholding](https://gra.gov.gh/domestic-tax/tax-types/vat-withholding/) |

Act 1151's text: [ATLA's copy](https://www.a-tla.org/ghana/value-added-tax-act-2025-act-1151).

## What Tabula does

- **Tutelora registers before the first charge.** Billing's switch stays off until it holds a VAT registration, and the VAT number is required to switch on.
- **Prices exclude tax, and the tax is shown before paying:** the plan's price, NHIL, GETFund, VAT and the total.
- **Rates are data with dates, not constants.** They changed in 2026, and an old invoice must keep the rates it was issued under.
- **Every tax invoice is cleared through E-VAT before it's issued as one,** by integrating with the GRA, not by the free application, because renewals issue invoices with nobody present.
  The invoice is numbered at payment and cleared by a queued job behind a driver (`log` in development); until the GRA answers, the paper is a receipt, not a tax invoice, and a failure
  retries and tells the Service (TB-14, 7 November 2026). Desk's invoices don't do this, so it's new work. Refunds get credit notes through the same route (TB8, 8 November 2026): numbered `CN-…` from
  their own gapless count, issued once the money has gone, reversing the invoice's price and each tax in proportion, a school's share of what it withheld shown apart. The GRA's
  specification for a credit note (the flag or reference it wants) comes with E-VAT access; the `gra` driver refuses until then, as for invoices.
- **A school can withhold.** A payment can be marked as net of 7.5% withholding tax, or of 7% withholding VAT. The period starts on the net payment; the withheld part stays open
  for 30 days (a setting) until its certificate is uploaded, and the Service is told if it lapses (TB-15, 7 November 2026). The plan is never taken away for the paperwork, so a
  school's correct deduction never reads as an underpayment that drops it to Free.
- **Each period is a tax event,** so the renewal, not the first sale, is what the invoice and the return follow.
- **A monthly report** gives the return's figures. Filing it stays Tutelora's job.

**Built in TB4 (8 November 2026).** Invoices are numbered at payment (`INV-2026-0001`, a gapless count a year), kept with the parties as
they stood, and sent to E-VAT by a driver: `log` in development, and `gra`, which refuses until the GRA's access and specification come, so
until then every invoice stays a receipt and is sent again hourly. Withholding tax (7.5%, offered on a price over GH₵ 2,000) and
withholding VAT (7%) are rows in `tax_rate` (kind `withholding`), worked on the price before tax, as the approved mockup does; which base the
law means is still open (above). The monthly report is not built yet.

## Not established

- **Which E-VAT batch Tutelora falls in.** The GRA onboards in batches, and I found no current list.
- **Whether Tutelora Limited is already registered for VAT.** That's not visible from here. If it's already making taxable supplies, the 30 days may already be running.
- **Whether schools are appointed VAT withholding agents.** The GRA's page says "some persons" and I found no list. Tabula allows for it either way.
- **Whether 7.5% is worked on the amount before or after VAT and levies.** The sources don't say.
- **Whether any exclusion covers a school as a withholding payer.** The rule covers non-individual residents, and none I read excludes schools.
- **Customers outside Ghana,** and how a foreign customer's supply is treated. Tabula assumes Ghanaian customers in cedis to start.
- **Penalties for invoices.** The GRA's penalty table still cites the old Act, so only s.16 is quoted above.