i) Security on Landed Property for Unpaid Tax:

• Notice of Intention: Where a person who is the owner of land or buildings situated in Ghana fails to pay tax when it is due and payable, the Commissioner-General may, by notice in writing, notify that person of the intention to apply to the Chief Registrar of Lands for the land or buildings to be the subject of security for tax as specified in the notice.
• Failure to Pay: If the person on whom the notice has been served fails to make payment of the whole amount of tax specified in the notice within thirty days of the date of service of the notice, the Commissioner-General may issue a “notice of direction” to the Chief Registrar.
• Registration of Security: Upon receiving the notice of direction, the Chief Registrar is required to register the direction as if it were an instrument or mortgage over the land or buildings, and this registration operates as a legal mortgage to secure the amount of unpaid tax.
• Cancellation of Security: Once the tax secured under the landed property is paid in full, the Commissioner-General is obligated to serve notice on the Chief Registrar to cancel the notice of direction, and the Chief Registrar will record the cancellation, thereby releasing the security.

ii) Recovery of Tax from Persons Owing Money to the Tax Debtor:

• Notice to Third Parties: Where a tax debtor has not paid the tax due, the Commissioner-General may issue a notice in writing to any person who owes or may owe money to the tax debtor, holds or may hold money on behalf of the tax debtor, or is authorized to pay money to the tax debtor.
• Requirement to Pay: The notice requires the person addressed to pay the money owed to the Commissioner-General on a specified date, up to the amount of tax due.
• Timing of Payment: The date specified in the notice cannot be earlier than the date when the money becomes due to the tax debtor or is held on their behalf.
• Notification and Compliance: The person served with the notice must notify the Commissioner-General if they are unable to comply due to lack of funds owed to or held for the tax debtor. The Commissioner-General can accept this notification and amend or cancel the notice, or reject it.
• Indemnification: A person making a payment pursuant to a notice from the Commissioner-General is deemed to have acted under the authority of the tax debtor and is indemnified against all civil or criminal proceedings related to the payment.