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5.5. Source Rules with Respect to Income Derived by Non-Residents

Income earned by non-residents from sources in Ghana is subject to tax in the country. In particular, the following income categories are deemed to be sourced from Ghana:

a. Dividends paid by a resident company;

b. Interest paid by a resident person or the Ghana PE of a non-resident, or on debt secured by immovable property situated in Ghana;

c. Payments made in respect of, or computed by reference to natural resources located in Ghana (including its territorial waters);

d. Rents for the use, the right to use or the forbearance of an asset situated in Ghana;

e. Royalties for the use, the right to use or the forbearance of an asset situated in Ghana;

f. Premiums for general insurance in respect of the insurance of risk in Ghana, or proceeds paid by a person to an insured person in respect of the insurance of a risk in Ghana;

g. Payments received by a person with respect to (i) the carrying of persons, cargo, mail or other tangible movable assets from Ghana other than as a result of transshipment, or (ii) the rental of containers or similar equipment that are supplementary or incidental to the business referred to under (i);

h. Payments received by a person in the business of telecommunications in respect of the transmission, reception or emission of messages by an apparatus located in the country, whether or not the messages originate, terminate or are used in Ghana;

i. Payments related to the exercise of a payment to the extent the employment is exercised in Ghana, or the payment is made by the Government of Ghana; or

j. Any other payments brought into or received in Ghana by a resident person.