Ghana lost GH¢2.7 billion to fuel tax evasion and regulatory margins from 2015 to 2018, a 2018 Chamber of Bulk Oil Distributors Industry Report has stated.

According to the report, the amount was from official unaccounted stocks and accounted sale volume.

For the period 2015 to 2018, total taxes evaded based on official unaccounted stocks stands at GH¢1,390.73mn while total under-reported taxes based on official accounted sale volume after adjustments for exemptions stands at GH¢1,168.33mn.

This implies that the country has lost a total of GH¢2,559.06mn in taxes for the period 2015 to 2018 when the petroleum tax regime was materially varied upwards, first with the SPT in December 2014 and the ESLA in December 2015.

Combined with the evaded regulatory margin of GH¢231.53m, a total GH¢2,790.59m has been lost to the nation in taxes and regulatory margins for the period 2015 to 2018.

NPA and savings

Despite this loss, the country was able to save about a billion cedis which could have been lost through smuggling of the products.

The report showed that due to the activities of the National Petroleum Authority with the collaboration with other government agencies managed to block the sale of these smuggled products.

The report also showed that in 2018, no loss related to unaccounted stocks is estimated as it was revealed that 574.25mn litres more than the official stocks saleable in the country were sold.

This indicates that smuggled stocks in the monitored depots must have been trapped as a result of the NPA’s regulatory interventions to curb the illicit trade of petroleum products and forced to be sold through official channels. This nonetheless did not eliminate the under-reporting of taxes on official sales by GHS433.75mn in 2018 after adjusting for tax exemptions and waivers.

A reconciliation of official national stocks movement data revealed that 54.36mn litres, 168.48mn litres and 794.75mn litres could not be accounted for in 2015, 2016 and 2017 respectively.

The associated petroleum tax revenue evasion to these stocks stands at GHS1,438.75mn while the associated evaded regulatory margins amount to GHS238.96mn.

The NPA, aided by elements of the central government made progress towards tackling the challenges of smuggling and tax evasion some of which were covered in the 2017 CBOD industry report.

This was a welcome move in the industry and yielded tangible results even though there remains a lot to be done to bring sustainable finality to the illegal trade. The interventions by the NPA minimised the evasion of official channels of distributions and hence an increase in official volumes of the most tax-evaded products, AGO regular and PMS, which shot up by 17% and 19% respectively.

Clearance of BDC debt

The report showed that a total of $929.58million has been paid between 2011 and September 2019 with a total of $52.62million outstanding and expected to be paid by year-end 2019.

However, a total haircut accepted by BDCs amounts to $432.00mn. This showed that progress has been made by the government in clearing the legacy debts to BDCs with the payment of all outstanding principal sums ($427.11mn) and the validation of the interest components.

Consumption levels in the country

Ghana’s gross national consumption reached 4.46mm mt in 2018. A total of 3.73mn mt was consumed by the non-power sector representing 83% of gross consumption while 738,076 mt (17%) was consumed by the power sector (fuel oil for power plants, crude for power and propane).

The report showed that petroleum products consumption in 2018 was about 3.88mn mt, 12.3% higher than 2017 consumption of 3.46mn mt.

This rode on the back of successes realised in the fight against the illicit petroleum trade, thereby increasing official demand for gasoline, gasoil and LPG. This volume of consumption is the highest observed to date. In terms of storage, the capacity reached 2.18mn m3 in 2018 from a national storage capacity of 2.093mn m3 in 2018. This followed the completion of a 69,059m3 storage capacity by Quantum terminals and GOIL’s 13,500m3 Marine Gasoil Facility at the Takoradi Habour.

Industry share

The BDC market consolidated with the top 10 increasing their cumulative market share from 78.65% in 2017 to 80.13% in 2018 according to the report.

In a similar trend, the top 5 also increased their grip on the market from 56.94% in 2017 to 59.63% in 2018. 27 BDCs distributed products above 10,000mt in 2018, while 11 distributed products below 10,000mt. Eight BDCs were inactive during the year.

 BDC Premiums

BDC premiums in 2018 were relatively lower compared to 2017 premiums. On average, gasoline premiums witnessed a 1.27% decrease in premiums reaching an average of $65.75/mt in 2018 from $66.60/mt in 2017.

Gasoil premiums dropped by 27% in 2018 averaging $49.23/mt, which is $15/mt lower than premiums observed in 2017.

The data showed that gasoline premiums recorded are 41% below the NPA benchmark premium and 18% below the CBOD breakeven benchmark premium. These low premiums observed are of extreme concern to the viability of the BDC industry.

Contrary to expectations that deregulation will enhance the commercial viability of BDCs as a result of the elimination of unfunded subsidies, it is increasingly evident that excessive competition among BDCs is yielding significant trading losses which are unsustainable by the equity capital of BDCs.

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