(1) Subject to subsection (2), in proceedings on appeal under section 41 to 45 or for the recovery of tax under a tax law, the burden of proof is on the taxpayer or person making an objection to show compliance with the provisions of the tax law

(2) With respect to the imposition of a penalty, including in proceedings on appeal under or for the recovery of a penalty, the burden of proof is on the Commissioner-General to show non-compliance with the provisions of the tax law.

(3) Section 41(4) provides for conclusive evidence that a tax decision has been made and is correct.

(4) The following matters are evidence in proceedings referred to in subsection (1) or with respect to an offence under a tax law:

(a) matters certified in writing by the Commissioner-General acting in an official capacity, including

(i) the name and address of a person and the amount and type of tax payable by the person;

(ii) a statement that a person has failed to file a document, register or otherwise comply with an obligation under a tax law;

(iii) a statement that a person is a tax officer and is authorised for the performance of specified activities under a tax law and that specified activities of the tax officer were performed in the pursuit of that authority;

(iv) a statement that a printed document is an accurate copy or translation of another document, including an electronic document or a document in code or in a foreign language; and

(v) a statement as to the value of goods;

(b) matters certified in writing by other Ghanaian public officers acting in an official capacity;

(c) matters certified in writing by a public officer of a foreign government acting in an official capacity; and

(d) proof of the content of ten percent of goods with respect to evidence of the remaining contents of goods seized under a tax law.

(5) This section applies to proceedings to enforce an obligation with respect to a security in favour of the Commissioner-General.