Import undervaluation being tackled

Mr. Bismark Kissi, Chief Revenue Officer, Customs Division, GRA

…as CTN exposes culprits

It has emerged that the implementation of the Cargo Tracking Note (CTN) policy is improving the capacity of the Ghana Revenue Authority (GRA) through its Customs Division, to identify imports which have deliberately been undervalued by the importer.

Shippers and their clearing agents commonly attempt this practice in order to reduce the import duty payable on the goods being imported.

Mr. Bismark Kissi, Chief Revenue Officer of GRA’s Customs Division has revealed that CTN documentation requirements are exposing possible import valuation discrepancies that suggest deliberate falsifications of applicable import values.

Giving a recent example of this he mentioned he was recently informed that with regards to a CTN document someone had seen, the value as per the CTN differs from what is on the invoice; the one that had been submitted per the invoice was lower than that stated on the CTN.

He warned that Customs has the ability to identify clear cases of under invoicing and when it does, it would take appropriate action to ascertain the correct value of the consignment being imported, with a view to imposing the proper import duties that should be applied.

This is similar to the use of benchmark valuation for ascertaining the correct import duty obligations of importers suspected of engaging in deliberate undervaluation of their goods, as being applied by Customs, prior to the introduction of CTNs.

“The GRA has historical data in our system” he explained. “If per your historical data, you have been bringing computers at US$10 and with the CTN you submit a value of US$2, then there is the need for us to interrogate the issue”, adding, the authority will go ahead to investigate further with all the needed values that is in their system, including the benchmark value.

This was revealed during a stakeholder forum aimed at finding the balance between trade facilitation and revenue mobilization organized by policy and education think tank, IMANI Africa in Accra.

The CTN policy was introduced to track all imports to Ghana. This according to the government would reduce revenue losses and various bottlenecks associated with under declaration of goods at the ports.


During the stakeholder forum, Mr. Kissi stated that the authority has started with the CTN and is interrogating the values that come onto their system, but could not confirm as to whether benchmark values derived from Custom’s database were being used.

“Once you have stated your value on the CTN, I don’t see the reason why any other person will go outside the CTN documents and apply the benchmark value. Probably that will only happen if there is suspicion that something is wrong”, he said, asserting, “it is what we receive practically”.

However, importers are still giving cause for such suspicions and as expected the use of the CTN system is increasing the exposure of deliberate under valuations such as with the example given by Kissi of different values on one importer’s invoice and the accompanying CTN.

By Dundas Whigham