High Court quashes GRA’s $800M tax claims against Mohameds

July 2 2026

The High Court has struck down the Guyana Revenue Authority’s (GRA) decision to impose more than $800 million in taxes on sisters Hana Mohamed and Bibi Mohamed over the importation and use of two luxury vehicles, ruling that the Tax Authority acted unlawfully in its handling of both matters.

In a ruling delivered on Friday, Justice Gino Persaud found that the GRA failed to act fairly and within the bounds of the law, granting several orders that nullified the tax assessments and permanently barred the agency from seizing the vehicles involved.

The case stemmed from the GRA’s March 2025 decision to accuse Hana Mohamed, sister of Opposition Leader Azruddin Mohamed, of breaching the conditions attached to a duty-free concession granted under the re-migrant scheme for the importation of a 2020 Ferrari.

The Authority claimed Hana Mohamed failed to satisfy the requirement of residing in Guyana for at least 183 days annually during the concession period and subsequently sought to recover approximately $479.7 million in taxes.

However, Justice Persaud ruled that the Commissioner General failed to properly exercise his discretion by not adequately considering Hana Mohamed’s explanations for her temporary absences from Guyana. The judge described the GRA’s actions as “unreasonable, arbitrary, irrational, unfair, and unlawful.”
As a result, the Court quashed the tax assessment of $479.7 million, overturned the GRA’s order requiring Hana Mohamed to surrender the Ferrari to the agency’s Law Enforcement Division, and granted a permanent injunction preventing the Revenue Authority from seizing the vehicle.

In a separate but related matter, the Court also ruled in favour of Bibi Mohamed, who had imported a 2023 Rolls-Royce under the same re-migrant concession programme.

Justice Persaud found that the GRA’s requirement that the vehicle be used exclusively by Bibi Mohamed as her primary mode of transportation had no legal basis. He also ruled that the agency’s requirement for her to report in person every six months for inspections was not authorised under the Customs Act.

The Court quashed the approximately $320 million tax assessment against Bibi Mohamed and granted a permanent injunction preventing the GRA from seizing her vehicle.

Attorney-at-Law Siand Dhurjon, who represented the Mohamed sisters alongside Attorney Damien DaSilva, welcomed the ruling, describing it as a significant decision that reaffirmed the limits of the GRA’s powers.

He noted that the Court made it clear the Revenue Authority could not ignore reasonable explanations provided by applicants before imposing tax liabilities and that several conditions recently imposed on re-migrant vehicle concessions were found to have no statutory basis.

According to Dhurjon, the Court ruled that requiring re-migrants to present themselves and their vehicles to the GRA every six months, as well as mandating that concessionary vehicles be used exclusively as a primary mode of transportation, were conditions “unknown to law” and therefore unlawful.

While the Court set aside the tax assessments and enforcement actions, Justice Persaud remitted Hana Mohamed’s matter to the Commissioner General for reconsideration in accordance with the law.

The judge directed that the GRA must fairly consider her reasons for temporary absences from Guyana, provide her with a reasonable opportunity to make further written representations, and take into account all legally relevant considerations before making a fresh decision.

Justice Persaud emphasised that his ruling does not require the Commissioner General to decide in Hana Mohamed’s favour but stated that any future decision must be made lawfully, fairly and rationally.

The High Court also ordered the Guyana Revenue Authority to pay the respondents $1.5 million in legal costs.