Ghana: Real-time VAT collection on cross-border digital services

The Ghana Revenue Authority (GRA) on October 15, 2026, introduced its real-time VAT (RTVAT) framework, powered by the Sentinal system. Under RTVAT, the customer's bank, mobile money operator, or other payment provider withholds the VAT on qualifying cross-border digital services at the point of payment and remits it to the GRA. Previously, collection depended on nonresident suppliers charging and remitting the tax themselves.

Background

Since 2022, nonresident providers of digital services and electronic commerce supplying customers in Ghana have had to register for VAT, with no registration threshold. According to the GRA, about 92 nonresident digital service providers are registered and remitting VAT. The GRA has identified about 100 others that are not charging VAT and says it will bring them into compliance progressively. The GRA describes RTVAT as a new way of collecting an existing tax, not a new tax.

Scope

RTVAT applies when the following three conditions are met: (1) the payment instrument is issued in Ghana (a bank card, mobile money account, or digital wallet), (2) the merchant is nonresident, and (3) the service is supplied electronically. The GRA's examples include streaming and subscription services, cloud services, online gaming and online marketplaces. The GRA has stated that the system does not apply to imported physical goods, which remain subject to Customs procedures. The GRA has published a non-exhaustive list of in-scope merchants.

Who collects?

Banks, payment service providers and aggregators, electronic money issuers, third-party payment processors, and other licensed payment institutions that process qualifying transactions must integrate with the system. They collect the VAT and remit it to the GRA. Customers are notified of the deduction by SMS or email.

Pricing

Registered digital service providers must display prices exclusive of VAT and inform customers that VAT applies at the point of payment. For example, for a service priced at GH¢100 before tax, the customer pays GH¢120. The merchant receives GH¢100, and the payment provider remits GH¢20 to the GRA.

Transactions performed by VAT registered nonresident digital services providers

RTVAT applies to both registered and unregistered nonresident providers. It does not remove the obligation to register and file monthly VAT returns. Detailed procedures for crediting and reconciling VAT withheld under RTVAT against a supplier's returns have not yet been published. It is expected that VAT withheld in real time will be recorded against the supplier's taxpayer identification number (TIN) so that it matches the liability per the returns. A supplier that is required to register but does not may face a penalty of at least three times the VAT payable, running from when registration was required until the supplier applies. The nonresident may also face a restriction of access to the country until it registers and settles any penalties.

KPMG observation

For foreign businesses selling digital services to Ghanaian customers, RTVAT is largely a change in how VAT is collected, not a change in what is owed. It does not create a new tax and does not replace the existing registration obligation. Nonresident suppliers of digital services have had to register and file returns since 2022, and the GRA has said RTVAT applies to both registered and unregistered providers. Unregistered suppliers should expect tax to be collected from their Ghanaian customers whether they have complied, and should still consider their exposure to registration penalties for past periods. For registered suppliers, the main impact is on pricing, cash flow, and reconciliation.

Affected businesses should reconcile payment remittance reports against invoiced amounts to confirm the correct VAT and levies are being withheld. They should also review pricing and invoicing practices and check agreements with payment processors and acquiring banks for updated remittance and reporting terms. A key open question is how VAT withheld through RTVAT will be matched to the supplier's monthly returns. The GRA has not yet published detailed procedures for crediting withheld amounts to the supplier's TIN, so registered suppliers should avoid double-reporting or double-paying the same tax until this is clear.

Businesses should also look at two areas of uncertainty. First, because payment data rarely shows the nature of a purchase, there is a practical risk of misclassification (under- or over-withholding) until the way in-scope merchants and transactions are identified is better understood and tested. Second, the treatment of business-to-business sales is unclear. A VAT-registered Ghanaian customer paying by corporate card could face both RTVAT withholding and self-accounting under section 61. It is also uncertain whether tax withheld through RTVAT supports an input tax claim, since section 56 relates to VAT certificates issued by appointed withholding agents. Further GRA guidance is expected on both points, and suppliers with significant Ghanaian business customers should expect questions from them. Finally, RTVAT is tied to Ghana-issued payment instruments, not the statutory place-of-supply test, so some transactions may be taxed through RTVAT even where the supply would not otherwise be treated as made in Ghana. Refunds in these cases may require engagement with the customer's bank or the GRA.

For more information, contact a KPMG tax professional:

Philippe Stephanny | philippestephanny@kpmg.com

Charles Frimpah | cfrimpah@kpmg.com