Dear Hon Majority Leader,
Firstly of all, let me digress by using this opportunity to express my gratitude to your friend, the Hon Speaker of Parliament for exhibiting a high level of maturity on a constitutional matter that can only be challenged legally at and determined or resolved only by the Supreme Court. It is heartwarming to note that in order to avoid legal battles that may lead to the shutdown of government in 2022, the Hon Speaker adopted a conciliatory path to resolve the seemingly impasse in Parliament, which had the potential risk of derailing the Fourth Republic, which some of us fought to bring about and will not allow bad nuts to terminate the Fourth Republic.
So, unless tested at the Supreme Court, Ghana’s democracy has won (a win-win for both sides of the House) due to the level of maturity exhibited by the Hon Speaker. Hence, the Leadership of Parliament agreed that the Finance Minister to re-submit the 2022 Budget, may be the modifications and concessions on the thorny areas for the adoption by the House. So, like what the Asantehene has said, we all expect the Finance Minister rather the President of Ghana to take the concerns of stakeholders on board for everyone to join him to champion for a good cause.
Hon Majority Leader, as a constructive citizen and not a spectator as urged by His Excellency President Nana Addo, the Show boy of Africa, I wish to bring to your attention as the Hon Minister of Parliamentary Affairs of some pertinent national issues on the 2022 Budget, especially the 1.75% electronic cash transfer levy (hereafter 1.75% e-levy) and the proposal for the abolishing of the Road Tolls in the 2022 Budget for the critical thinking on the associated matters by Parliament.
The Hon Majority Leader as you are aware the Mobile Money Platform executed by the Tele- Communication Companies is simply a medium for Mobile Financial Services including the effecting of Bank Credit (loan). So it enables the users at any location within the network to send, receive in a wallet and spend (withdraw) cash instantly. This fast transfer/withdrawal of cash affords the benefits of eliminating or reducing the associated risk in financial matters especially the risks of banditry activities (stories of pickpocketing, robbery of cash during carriage or transfer etc), stories of misapplication, loss or non-delivery of the cash by errand boys or carriers etc. Hence, Mobile Money Platform also helps greatly in improving security and safety.
Hon Majority Leader the intent to introduce the 1.75% e-levy on electronic-transactions especially mobile money payments (sending cash on the mobile money platform) may reduce confidence in the MoMo system and people would revert to the cash carriage system with its
associated risks hence counterproductive. This will hurt the national economy because it may cause a reduction of the numerous employment in the MoMo business, it may reduce the proximity to (the doorstep) access to ones funds created by MoMo Merchants thus slow down business activities, it may disable fast credit facilities like Quikloan business which is affording huge loans to some of the citizenry especially people who are not on pension and have lost their investments or yet to be bailed out by the State like myself, small business holders ( some market women), it may put some single mothers and widows in serious financial crisis, consequently lack of productive business, will have a devastating or negative effect on another tax namely VAT returns (Consumer tax due to low demand for VATABLE goods and services). Lastly, It would also hurt the attempt in attaining full financial inclusion or the digitalization process due to a serious debilitating effects on the finances of the citizenry and thus forcing the citizenry to navigate back to the cash carriage system in order to retain the value of their income that is to prevent partly loss to the obnoxious 1.75% e-levy.
Hon Majority Leader, the effect of this envisaged greedy scheme (venture or what may be termed as a daylight robbery), beside the implication of insecurity especially vulnerability will destroy the huge investments on both the digitization and the digitalization processes thus it will derail the attempt to attain an almost cashless society which among others, as a measure to reduce the high cost of printing new banknotes to replace worn out banknotes, as well as a reduction or a control measure of the associated security risks and a derailment of the digitalization process will not give a clear picture for a good decision on national economy.
Hon Majority Leader, the Hon Finance Minister read clearly to our hearing that it will affect all E- transactions. All is a Universal Set in Arithmetic hence the national economy will be hurt. He even went further to elucidate the Subsets of the Universal set namely MoMo Transactions, Merchant payments, Banker Transfers, Remittances etc.
He indicated that it would affect only the sender and not the recipient. Hmm, he needs to give a second look on the matter because both the sender and recipient will be affected in a medium for a chain of electronic-transfer transactions since the recipient automatically assumes the status of a sender on receipt of the cash in his or her electronic wallet, which will not be kept for a longtime like in a bank account so he or she will decide or be required to send to another MoMo account or bank account due to the interoperability, hence the 1.75% e-levy will have a cascading effect on the income of the citizens in their electronic-wallets (e-wallet). Hence, they may opt to move to the cash carriage systems.
Hon Majority Leader, I am totally in agreement with the Ashantehene (a man of great wisdom) that the citizens must be taxed or pay tax for national development. But I will like to go further to say that the tax must be reasonable, simple to compute and must not be seen wasted but used judiciously when collected. So, I am recommending a start with a very low rate between 0.2% and 0.5% on all e-transactions, it should affect only the withdrawing of cash from ATMs, e-switch and e-Wallets therefore the Recipient or the withdrawer and not the sender should pay the tax when withdrawing the cash.
Hon Majority Leader, this is very necessary to avoid multiple taxing of the same amount in the chain of electronic-transactions or electronic-transfers and thus appear as a punishment for using very a good medium in financial transaction necessary for financial inclusion. It also requires an element of discrimination to protect the poor, by granting some exemptions to net wages after PAYE etc deductions being paid or send by MoMo by an employer to employees say pastors and or private security guards deployed at far remote areas where no bank exist in order to prevent the debilitating effect on their very meagre income. Lastly, one may an important need to avoid taxing the payment of credit especially loan transactions. Taxing one suffering to pay back his loan may be traumatic hence counterproductive.
Hon Majority Leader, the e-transaction among others, is a medium as stated for sending and receiving payments of credit including loan, it is used for the purchase of power or payment of utility bills, payment of contributions example funeral contributions and effective January 2022 an additional platform for the payment or collection of SSNIT Contributions and could even be used by the State for easy payment (collection) of tax by GRA or levies by District Assemblies etc or payments to same. So the State should not do anything that may devastate the e-transaction especially e-transfer on the MoMo platform.
Hon Majority Leader, the above details and subsequent submissions demo that no critical thinking was done on matters on the e-transaction, which also involves two important elements namely the creditor (lender or loaner) and the debtor (or burrower or loanee) and that any of them can become the sender when granting the loan (done by the lender) or when paying back (refunding) the loan by the burrower or refund of a loan (cash receipt) by a wrong recipients of a loan due to technical error. That is to say the loanee or borrower who receives credit therefore designated as a Recipient will virtually become the sender when servicing or paying or returning the loan, so he or she automatically assume the position of the sender on receipt of the loan, because the loan can be serviced on the same day or returned on the same day by a wrong recipients or by a recipient who is ok and does not need the loan. Hence, I reiterate my strong recommendations that the e-levy should be as low as 0.5% and restricted to when withdrawing and an element of discriminatory to arrest its effect on loans, net wages after payment of PAYE.
Hon Majority Leader, why should the State tax a loan or credit facility that is to say why do you tax a creditor when granting a loan through a fast medium since it will affect the interest rate or/and why do you tax the debtor when he or she is struggling hard to service or pay his or her loan or credit (note some people or companies took 5 years or so to pay their loans even at a very reduced interest rate by the lender). Hence, this obnoxious/draconian tax (the 1.75% e-levy) will have serious repercussion on the credit system. Evidenced by a report in the media that the General Manager of Quikloan Service indicated that his firm may stop the loan facility, if the 1.75% e-levy is implemented thus affecting the interest of the citizenry especially poor women who may need quick loan or quick credit facility through e-transaction, hence high level of prostitution as well as the destruction of the fabric of the society especially marriage is envisaged.
Hon Majority Leader, I wish to reiterate that since in Financial transaction we have three functions sending, receiving and withdrawing especially with ATM Card or spending with a credit
card, so the wiser thing to do is to impose the e-levy during withdrawing of cash only on the electronic transactions and it must be as low as 0.5% to be tolerable by everyone, otherwise anything short of this will lead to serious agitation 24/7/365 in 2022 by some citizenry especially those of us whose life investments are yet to be retrieved or yet to be bailed out by the State and thus surviving on some support through MoMo from friends and relatives or Quikloan, Xpressloan etc facilities from MTN, Ecobank etc. Hence, the 1.75% e-levy may be counterproductive thus hurting National economy virtually National Security or cohesion of the State for National Development will be disturbed.
Hon Majority Leader, it is feared as stated above that lenders of fast or quick loan say Quikloan (MTN), Xpressloan (Ecobank) using the platform designed by the Telecommunications as a medium for fast cash transfer may to stop the operations of their loan facilities. That is if a compromise is not reached between them and the State on matters on the 1.75% e-levy. Hence, the State through the Executive arm of Government failing that then Parliament, with you as one of the major leaders and s stated by the Ashantehene must engage stakeholders and take our concerns on board to come out with reasonable modification on the 1.75% e-levy.
Hon Majority Leader, if the 1.75% e-levy causes the stoppage of the Quikloan facilities, then some of the citizenry will demo 24/7/365 against the 1.75% e-levy therefore the government, because the stoppage of the Quikloan facilities will affect our survival or interest. And to my good friend/brother Mr IGP, this is not a threat but a promise since committing suicide (as it was sadly committed by some colleagues who also lost their huge investments) is not and will never be an option to some of us whose investments are in deadlock). Thanks to Almighty God and the proponents of the 1992 Constitution for granting everyone the right to demonstrate to in order to preserve, uphold, protect and defend one’s right to survive in order to prevent darkness to cover one’s light and turn one’s day to night (courtesy Concrete Jungle lyrics by Bob Marley).
Hon Majority Leader, the 1.75% electronic levy (e-levy) as explained will be a regressive tax, double taxing people or it will tax one’s income several times in a medium, made for transferring cash from an account to another account. Thus, it would have serious effect on all sorts of MoMo payments.
Hon Majority Leader, it also going to be taxing another tax namely VAT especially when paying by the MoMo system for the cost of goods which include the VAT element. This may therefore be envisaged as a penalty for use of the MoMo system.
Hon Majority Leader, let us look at a scenario. Currently (in December 2021), if a Koko seller at Edwinase near Agric Kwadaso in Kumasi, is to pay GHC600.0 as the medical bills etc for the son at Kejetia or Adum in Kumasi, it will be better for her to send the money on the MTN’s MoMo platform by topping up with GHC6.00 against MOMO transaction fees on the MTN Platform, to make the amount as a total sum of GHC606 and send the GHC606.00 by MoMo for the son to receive the exact amount of the GHC606.00 in his e-wallet but he is entitled to withdraw only GHC600.00 at Kejetia. This afford the lucrative chance of not stopping or suspending her business for avoiding the use of an errand boy or carrier at a total (going and returning) cost of GHC4.40
by trotro, to send the money to the son at Kejetia and reduce the likely associated risks including misapplication, or non-delivery of the cash.
Hon Majority Leader, but with 1.75% e-levy, she going to face very serious problems on the initial transfer of GHC606.00 on the MTN Platform for a day for the son to get GHC600.00, because of her need for additional cash against an expected direct additional loss to her of GHC8.86 = 1.75% of 506 that is 1.75% of (GHC606.00 minus GHC100.00 as the initial transfer for the day = GHC506.00) coupled with problem of computation, please note every cent or pesewas matters very much to the Koko Seller, so to avoid these encumbrances, she may decide or she may be better off to send the cash to the son at Kejetia which will cost her GHC4.40 by trotro to go to Kejetia and return to Edwinase and save a total sum GHC10.46 which maybe not be up to her profit or the sale price of her Koko for the day.
Hon Majority Leader, please note that when the 1.75% e-levy is in operation, the electronic system is going to capture a total sum of GHC606, thus including the MTN fees and impose the 1.75% levy on GHC506.00 only which include the MTN’s fees as well. Thus she is now required to pay tax or levy on the MTN transaction fees of GHC6. She may also face of a headache or a problem of how his son will be able to meet the payment of the 1.75% levy in the chain of the e- transactions when paying electronic credits (E-credit) otherwise how the son will be exempted from the payment of the 1.75% levy in the chain of the e-transactions or how the son could dodge this draconian tax when the Pharmacy Shop at Kejetia demands the payment by MoMo. A very big headache (aba bonibeh oyeh to deserve this trauma), thus the state will be putting the citizenry in traumatic conditions thus counterproductive, hence, I strongly recommend that the e-levy should be reduced to 0.5 % and on Withdrawals only.
Hon Majority Leader, the lack of transparency (evidenced by the failure to engage stakeholders) by the Ministry of Finance or the government as at date has further worsened the situation so if things are not made clear by 01 January 2022, the slow loss in confidence by the citizenry in the MoMo transaction maybe aggravated thus counterproductive and may have serious implication on government machinery in 2022, consequently serious implication on National Security.
Hon Majority Leader, the roads built by the State need to be maintained through the payment of road tolls, so, I wish you could use your position as a cabinet Minister or get your colleagues in Parliament to get the Executive arm of Government to have a second look on matters pertaining to the proposal for the removal of the road Tolls in November 2021, since it was part of the area of expected revenue for the 2021 Budget read in Parliament by you, on behalf of the President during the leave of absence of the Finance Minister .
Mr Hon Majority Leader, the Government has a responsibility to ensure sanity, security and safety in the Country and these among others will require good roads, the provision of jobs through enabling environment. We were made aware that about 40 Toll booths were manned nationwide on some Highways and at some Bridges in Ghana. But due to some alleged hazards including slow flow of traffic, pollution and safety concerns, the Government of the Day has proposed to Parliament to abolish the Road tolls.
Mr Hon Majority Leader, the roads need to be maintained and the associated risks can be addressed by automation by electronic system. So, the Digitization and Digitalization processes by the Vice President should be employed in the management of the Road toll booths to maximize revenue, provide some employment and above all reduce the alleged associated risks. So I wish to recommend that the road tolls should be maintained rather re-introduced since it was illegally abolished. An improved electronic system and enlargement of some of the affected roads as stated could reduce the associated risk so that the accrual revenue should be dedicated to a budget line as Road Maintenance Fund. Hence, the about GHC80million or more that may be obtained yearly from some of the Highways/Bridges should be dedicated to a Road Maintenance Fund for the affected roads and bridges because the bad nature (potholes etc) of the Highways and roads at the Bridges maybe one of the contributing factors to the slow traffic movement.
Hon Majority Leader, at this juncture, I deemed it necessary as an honest person to make some disclosures. I vote for NPP by default (automatic) because of some problems in 1982 which made me to join the pressure group or forces in an attempt to restore the 1979 Constitution or install a new Constitutional Rule, hence against oppressive rule. So in 1982 whilst as a student at the then UST (now KNUST) especially as a student leader (a member of the Republic Hall JCR, precisely the Entertainment Chairman and a staunch member of the SRC Entertainment Committee) and with the support of the first FM radio facility in Ghana, namely Radio Continental at Unity Hall, together with others, we fought hard with all means at our disposal to see to the restoration of Constitutional Rule.
God heard our prayers and cries in 1992, so in 1992 a Consultative Assembly was established which by coincidence had my godfather and one of my Chiefs, the late Chiana-Pio namely Pe Roland Adiali Ayagitam 11 as the President of the Assembly that saw the drafting of the 1992 Constitution. So in 1992, I did swear to God on the onset of the fourth republic that I will uphold, defend and preserve the 1992 Constitution and always vote for the NPP even in the grave, so beside my survival as stated above, I am hereby kicking against an action by the Hon Finance Minister that initially had the potential to derail the fourth republic otherwise the potential to send the NPP into Opposition, hence my take on the matter to you.
Hon Minority Leader, I hereby urge you to get the proposed 1.75% e-levy reduced to 0.5%, it should be imposed on withdrawals, consideration of exemption to loan facilities by Quikloan, Xpressloan etc through the MTN etc platform, and lastly the automation of the toll booths for the reinstatement of the Road toll which must be designated and dedicated as Road Maintenance Fund for the maintenance of the affected roads.
Yours truly Signed
Major Mohammed Bogobiri (Rtd) Citizen Ghana