Dr. Delali Adzo Gawu is Ghana's first female homegrown PhD in Law and among KNUST's first PhD in Law graduates. Her research tackles one of Ghana’s most complex legal challenges: tax law complexity. “Tax laws are just of a different kind, quite difficult to understand, even for lawyers and experts,” says Dr. Gawu.
Her thesis titled, “Tax Law Complexity- An Examination of Ghana’s Source of Income Rules,” explores the practical and structural hurdles that taxpayers, legal practitioners, and judges face in trying to understand, interpret and apply Ghana’s source of income rules to allocate of taxing rights.
Her research shows that the source of income rules under the Income Tax Act, 2015 (Act 896), as amended, is uncertain in scope and that determining the originating cause of income has produced conflicting judicial decisions.
For the research, she interrogated the interpretive approaches used in Ghanaian tax cases and found them to be inconsistent with established principles in some instances.
On the relationship between tax policy and tax law complexity, Gawu notes that “I discovered that tax policy itself is a root cause of complexity.”
She examined the national tax policies of Nigeria and Kenya for their specific focus on tax law simplification, having noted Ghana’s limited tax policy attention to the subject.
Dr. Gawu emphasizes Ghana’s urgent need for a long-term, comprehensive Ghana national tax policy, with clear and actionable steps to tax law simplification.
Analysing the tax law rewrite projects of Australia, New Zealand and the United Kingdom for their efficiency in addressing tax law complexity, Gawu found that simplifying tax law without simplifying tax policy produced limited results.
She thus proposes a three-tiered approach to tax law simplification. She recommends that policy and lawmakers:
Simplify the tax policy itself by clearly defining national objectives and priorities, while also streamlining the law to make it easier to understand and apply without undermining its legal integrity.
It further emphasises the need to strengthen interpretation frameworks by equipping judges and tax authorities with improved tax knowledge and clearer guidance, enabling more consistent and predictable application of tax laws.
Dr. Gawu’s interest in tax law is deeply rooted in her academic and professional journey. “As a law student, later a lawyer, and now a legal academic, I realized that income tax law presents unique challenges for both teaching and practice,” she says. Her experience as a lecturer of the Law of Taxation informed her perspectives and enriched her research.
Balancing PhD work with family, teaching, and personal responsibilities was no small task.
“The support from family, colleagues, and supervisors was crucial,” she reflects. “Resilience and collaboration were key to completing this work.” She recalls moments during her research when methodological challenges and unforeseen obstacles threatened progress, but guidance from God and her supervisors helped her find solutions and stay on course.
Dr. Gawu’s research does more than analyse tax law complexity; it makes a unique contribution to the body of knowledge on tax law complexity by initiating the conversation in the Ghanaian context, offering actionable recommendations and providing a solid theoretical and practical basis for examining other income tax law principles and other tax types in Ghana and beyond.
“I want this research to be remembered as original and impactful,” she says. “It examines tax law complexity in Ghana and provides practical ways to simplify it, strengthening compliance and the rule of law.”
