Sierra Leone rewrites four zero-rated items in the GST Second Schedule

What changed in detail

Section 25 of the Finance Act, 2026 (Act No. 1 of 2026), gazetted 7 January 2026, amends the Second Schedule — the zero-rated list — to the Goods and Services Tax Act, 2009 in four places.

Item 4 (water) is repealed and replaced: the supply of water, including sachet water, but excluding bottled and distilled water and industrial, commercial and high-end domestic use.

Item 5 is repealed and replaced with “Mini grids renewable energy and solar home system”, covering (a) the consumption, supply or use of renewable energy from mini-grid-connected solar power in Sierra Leone, and (b) accessories and component parts of a solar-powered home lighting system comprising a solar panel, multiple LED lights, battery, inverter, charge control unit, casing and cabling, classified as zero rated under the Harmonised System code.

Item 21 (raw fish) is repealed and replaced: the importation or supply of raw fish as described under HS Code 1604.1, but excluding processed and packaged fish.

Item 29 is inserted immediately after item 28: equipment and accessories for clean cooking — LPG stoves and home-use storage and distribution components such as cylinders, regulators and hoses, and appliances that use LPG for cooking, classified as zero rated under the Harmonised System code.

Unless otherwise stated, the Act is deemed to have come into operation on 1 January 2026.

What it means

Two of these four are relief; two are restrictions wearing the same clothes. Items 5 and 29 add zero-rating for solar and LPG equipment. Items 4 and 21 keep zero-rating but carve out the commercial end of it — bottled and distilled water and industrial or high-end domestic water use leave the schedule, and so does processed and packaged fish.

The carve-outs are the risk. A supplier reading “water is zero-rated” or “fish is zero-rated” off a rate table will now be wrong for part of its range, and the distinguishing facts are packaging and customer use rather than the product itself. That is a product-master problem more than a tax-code one, and it has applied since 1 January 2026.