By LCN Wire
The Guyana Revenue Authority has asked the Court of Appeal to overturn a High Court ruling that quashed G$799.8 million in taxes on Hana Mohamed and Bibi Mohamed and barred the seizure of a 2020 Ferrari 488 and a 2023 Rolls-Royce Cullinan, HGPTV and Kaieteur News reported on 15 September. The GRA had claimed breaches of re-migrant duty-free concession conditions on both vehicles when it first moved to seize them in April 2025, Stabroek News reported.
The appeal reaches beyond the two cars. In July, Justice Gino Persaud struck down two conditions the GRA attaches to re-migrant vehicle concessions, finding that neither has a basis in the Customs Act. The ruling followed a December 2024 decision in which the acting Chief Justice found that a different GRA re-migrant requirement had no basis in law.
What did the High Court decide in July?
Justice Persaud ruled on 3 July 2026 that the GRA's enforcement was "unreasonable, arbitrary, irrational, unfair and unlawful", Kaieteur News reported. He found that the Commissioner General had failed to lawfully consider Hana Mohamed's reasons for her temporary absence from Guyana. He also declared that the GRA has no authority to require that a concession vehicle be used "solely by the applicant as her primary mode of transportation", or that its owner report in person every six months with the vehicle and its documents for inspection.
He quashed the G$479.7 million assessment on the Ferrari, registered PAD 5000, and sent Hana Mohamed's matter back to the GRA for fair reconsideration. He quashed the G$320 million assessment on the Rolls-Royce, registered PAE 5000, granted Bibi Mohamed a permanent injunction against seizure or forfeiture and awarded G$750,000 in costs. Stabroek News recorded the same two assessments in April 2025, when GRA officers and police twice tried to remove the vehicles from Opposition Leader Azruddin Mohamed's residence at Houston and withdrew after a crowd gathered.
What is the GRA arguing on appeal?
The GRA contends that Justice Persaud "erred in law and in fact", Guyana Times reported. According to HGPTV, the Notice of Appeal argues that the Commissioner General had authority to act once concession conditions were allegedly breached, and that the concession letters effectively created an agreement between the GRA and the re-migrants. It cites sections 36 and 209 of the Customs Act and asks the court to reverse the orders, dismiss the judicial review applications, lift the injunctions and set aside the costs. HGPTV reported that attorney S.A. Dhurjon has filed a cross-application on behalf of Hana Mohamed.
How does Guyana's re-migrant scheme work?
The Ministry of Foreign Affairs and International Cooperation decides who qualifies and the GRA sets and administers the tax exemptions, according to the Ministry's published guidance. A Guyanese citizen aged 18 or over who has lived legally abroad for at least five consecutive years, or three for a graduate, applies in person to the Ministry's Re-migration Unit within six months of returning, with a passport at least five years old, immigration travel records, evidence of how they will earn a living and a sworn statutory declaration that the goods are for personal use "and not for sale or exchange". The approval letter is valid for six months, and the GRA fixes the exemptions after examining the documents and interviewing the applicant. On a vehicle, customs duty and VAT are waived and excise is charged at 5 to 30 per cent according to engine size, under section 23(1)(c) of the Customs Act, according to the GRA's published policy. In return the owner must live in Guyana for at least 183 days a year and may not transfer or lease the vehicle for three years if it is used or five years if it is new; if those conditions are broken, the waived taxes fall due on a pro-rata basis. Neither the Ministry's guidance nor the GRA's policy lists either of the two conditions Justice Persaud struck down.
What misuse of re-migrant concessions has been reported before?
In 2014 Kaieteur News reported that GRA records showed a re-migrant who registered a duty-free Mercedes-Benz AMG SUV in November 2012, on condition that he present it and his passport every six months for three years, had never done so, and had by then spent 20 months overseas and four in Guyana. The same year, a column in Stabroek News by a former president of Transparency Institute Guyana described "widespread abuse of duty-free concessions being granted on motor vehicles", including the forgery of some 50 approvals for re-migrant status and private sales in which ownership passed to the buyer only after the duty-free period ended.
In February 2018 the GRA seized a Ferrari in a container at the wharf over paperwork discrepancies and a suspected arrangement to sell it to an auto dealer inside the three-year period, Kaieteur News reported, adding that the authority had seized seven vehicles and collected more than G$50 million the previous December.
In December 2024 the GRA said publicly that auto dealers and others were recruiting applicants with little financial history who received sudden, unexplained cash deposits, acquired luxury vehicles, passed them to ineligible buyers through powers of attorney and then left Guyana, Stabroek News and News Room reported. The authority said a regular importer could pay more than G$44 million in taxes on a high-end vehicle that a re-migrant could clear for about G$6 million. That statement followed a ruling on 3 December by acting Chief Justice Roxane George, who quashed the GRA's demand that re-migrant Reaz Manjoor prove the source of the funds for a 2023 Toyota Land Cruiser, finding "no provision known to law" for it and refusing leave to appeal, Stabroek News reported.
Where do the US sanctions fit?
The US Treasury's Office of Foreign Assets Control designated Azruddin Mohamed, his father Nazar Mohamed and their company Mohamed's Enterprise under the Global Magnitsky programme on 11 June 2024, alleging that the company paid bribes to officials to win government contracts and that Azruddin Mohamed and the company under-declared gold exports to evade Guyana's gold export tax. Neither Hana Mohamed nor Bibi Mohamed was named in the designation, which concerns gold and contracts rather than the vehicles. A US federal indictment against father and son followed in October 2025, Stabroek News reported.
An OFAC listing does not remove a political figure from public life. Colombia's Gustavo Petro was designated in October 2025 while still in office, and the most visible consequence was an airline cancelling his ticket.
What the title card shows
- G$799.8 million in tax demands quashed by the High Court in July 2026: G$479.7 million on the 2020 Ferrari 488 (PAD 5000) and G$320 million on the 2023 Rolls-Royce Cullinan (PAE 5000). Sources: Kaieteur News, HGPTV.
- In the published rules: at least 183 days a year living in Guyana; no transfer or lease for three years (used vehicle) or five years (new); waived taxes due pro rata on breach; excise of 5 to 30 per cent by engine size. Sources: GRA Tax Exemption Policy, February 2026, Ministry of Foreign Affairs guidance, March 2025.
- Struck down, July 2026: use solely by the applicant as primary transport; in-person GRA inspection every six months. Source: Kaieteur News.
- Quashed, December 2024: the GRA's source-of-funds requirement in Manjoor v GRA. Source: Stabroek News.
- Sections 36 and 209 of the Customs Act, cited in the GRA's Notice of Appeal. Source: HGPTV.
- Quotation: "unreasonable, arbitrary, irrational, unfair and unlawful", Justice Gino Persaud, 3 July 2026. Source: Kaieteur News.
Frequently Asked Questions
Who qualifies for Guyana's re-migrant scheme?
A Guyanese citizen aged 18 or over who has lived legally overseas for at least five consecutive years, or a graduate who studied abroad for at least three, and who applies within six months of returning, according to the Ministry of Foreign Affairs.
What conditions attach to a duty-free re-migrant vehicle?
The owner must live in Guyana at least 183 days a year and cannot transfer or lease the vehicle for three years if used or five years if new. Otherwise the waived taxes become payable pro rata, according to the GRA.
Which conditions did the High Court strike down?
Justice Persaud ruled that the GRA cannot require a concession vehicle to be used solely by the applicant as their primary transport, or require six-monthly in-person inspections, Kaieteur News reported.
How much tax is in dispute?
G$799.8 million: G$479.7 million on the Ferrari and G$320 million on the Rolls-Royce, according to HGPTV and Kaieteur News.
The Court of Appeal will now decide whether conditions the GRA writes into its concession letters can be enforced beyond those the Customs Act sets out.