In 2 Conrinthians 13:1b, the Holy Bible says “Every matter must be established by the testimony of two or three witnesses.”
On the basis of that biblical verse, when I discovered that there was illegal e-levy charges on no other platform than the government’s much-touted MOBILE MONEY INTEROPERABILITY (MMI) Platform, I made sure I got at least two more witnesses just to clear every shadow of doubt that indeed we are being charged e-levy illegally on that platform.
One would have thought that since the MMI platform, built and run by Ghana Interbank Payments and Settlements System (GhIPSS) of the Bank of Ghana, is under a state institution, that platform would have been one of the first to be linked to the e-levy Common Platform to ensure that anyone who uses that channel for transfers between wallets and accounts linked to same Ghana Card are exempted from e-levy per the e-levy law.
Sadly, that is not the case. On the contrary, several other private channels like bank short codes and telcos’ push and pull channels rather give e-levy exemptions, but the MMI is rather doing us damage, particularly those of us who save with banks, which only allow wallet to account transfers via the GhIPSS MML channel.
The reason I am compelled to write about this now is that after I discovered the illegal e-levy charges and went through two months of back and forth between all the four stakeholders, all of them admitted there must be a refund to me, but some of them kept pointing fingers at the other, while others became unnecessarily defensive of their platform, and others also chose the path of paranoia instead of focusing on the main issue. As a result, till date, the problem still remains unsolved. These are the sorts of hurdles that public spirited people come up against while trying to help solve a simple problem.
Now the details.
On June 2, 2022 (a month before the launch of the Ghana Revenue Authority’s E-levy Common Platform), I transferred GHS500 from my MTN MoMo wallet to my SG current account via the GhIPSS Wallet to Account Channel on the MTN Mobile Money USSD Menu found on short code 170.
Where can that channel be found?
1. Dial *170# and send
2. Select 1. Transfer Money
3. Select 6. Bank Account
4. You will see GHIPSS Banks transfer service – 1. Wallet to Bank Account
There is another channel on the MTN *170#, which is the traditional wallet-to-account and account-to-wallet channel from MTN itself, often described as the push and pull service. That one is on number 5. Financial Services.
The problem with that channel is that, not all banks are on it. My bank, Societe Generale is not on that channel, because the French owners of that bank are very strict on cybersecurity. They would rather use the state-owned MMI channel, instead of the MTN Push and Pull channel.
So, I had no choice than to use the MMI channel because that is where my bank is. When I transferred the money (GHS500) on June 2, I was charged GHS7.50 e-levy, even though I had linked my Ghana Card to my SIM Card in April and done same for my bank accounts in May. But I did not have any qualms because, at that time the E-levy Common Platform was not yet working. I was confident that once the Common Platform goes live, I will get a refund because both my account and wallet were linked to my Ghana Card.
July 1, 2022 came and the Common Platform went live. It took a while, but eventually there were refunds. I actually got some GHS1.50 refund for some GHS100 fuel I bought prior to July 1 and paid e-levy. But my GHS7.50 never came. So, I decided to reach out to all the parties involved in this transaction.
MTN – charging entity
My first point of call was naturally MTN – they were the charging entity because the transfer was from wallet (MTN) to bank account. After a long back and forth with a very helpful staff, I was directed to my bank to check if indeed they had linked by account to my Ghana Card, so I did and confirmed that it was done. In fact, later in the course of the several back and forth, I also confirmed from GRA that indeed, my account is linked to the Ghana Card. The final message I got an MTN top executive was that they only charge E-Levy based on the advice of GRA. But they promised to check why I did not get a refund.
GRA – witness number 1
In my frustration I decided to reach out to GRA. I was given one of the leading experts on e-levy to engage with. He did a very practical thing. He used the very channel I used to do a transfer from his own MTN wallet to his bank account and he was charged e-levy. So, he came back to me and said I was right, and the reason for the charge was that, MTN had failed to connect their MMI channel to the Common Platform, so transaction between wallets and accounts on that channel is not being recognized by the Common Platform as transactions that should be e-levy exempt. Clearly, GRA pushed the blame back on MTN.
I had no choice than to go back to MTN. and they flatly denied the accusation, saying that they had connected all of their channels to the Common Platform and they never apply e-levy to any transaction without GRA’s approval.
Remember that the transaction in question predates the Common Platform launch – it was on June 2, one month before the launch of the Common Platform. At the time there were no exemptions apart from the first GHS100 daily transfer. The issue here is for me to get a refund of a tax charged on a transfer, which became effectively exempted post Common Platform launch. But all the stakeholders keep waging a subtle turf war and throwing technical jargons around while that simple problem remained unsolved and still unsolved till date.
Paranoia
I was to go back to the GRA person and inform him about MTN’s response but he also decided to get paranoid and abandon me. I had made a Facebook post about the failure of e-levy to realize its GHS1.46 billion target in two months. Instead, it raked in an abysmal GHS93 million. This GRA staff had a problem with my post and therefore decided not to work with me on fixing the wrong e-levy charges happening on the MMI platform. I was really shocked to my bones that my assistance to get a problem solved would be ignored just because I exercised my constitutional right to an opinion about a national policy. That is what you get when you deal with paranoid public/civil servants.
GhIPSS – witness number 2
But it gets even more interesting. Recently, I also engaged a GhIPSS official who also decided to test the MMI channel I was referring to. She tried it and was also charged e-levy and she came back to me with a screenshot of her transfer and said “Sammy you are right”. But she still had no clue why there is e-levy on transfers between wallets and accounts linked to same Ghana Card on that channel, except to say MTN is the charging entity so they should be able to tell me why.
Obviously, her intervention was only as good as sending me back to the starting point of the vicious cycle which does not seem to have any end in sight. MTN – SG – GRA – GhIPSS -MTN, still no solution till date, yet everyone says “Sammy you are right.”
GRA, part of the snake eaters?
A popular Akan proverb says “if the elder sits by and watch the kids eat snakes without checking them, when the law catches up with the snake eaters, that elder will also stand accused as a snake eater.” GRA must prove to us that they are not part of the snake eaters.
I think GRA, which is the regulator of this whole e-levy thing, needs to sit up and take a critical look at why the MMI channel is charging e-levy on transfers between wallets and accounts linked to same Ghana Card. In my case, the charge occurred prior to the Common Platform launch. But even now that the Common Platform is here, the problem still persists.
This has obviously gone beyond finger pointing and blame game. It is not enough for GRA to sit back and point fingers at MTN and tell customers to go to MTN. The regulator must lead the way in finding a lasting solution to this anomaly. GRA needs to get its charging entities in line if it has to. MTN and the other charging entities do not charge and keep e-levy for itself. They do so on behalf of GRA, so GRA must act and stop MTN and other charging entity for that matter, from stealing our moneys for GRA, otherwise, when we point fingers at the snake eaters, GRA will be number one.
I rest my case.
