Ghana has won an international tax arbitration dispute with Tullow Ghana Limited after an arbitral tribunal ruled in favour of the Republic and upheld a US$393.09 million tax assessment against the oil producer.
The tribunal, constituted under the Rules of Arbitration of the International Chamber of Commerce (ICC), delivered its award on Tuesday, September 29, 2026, in proceedings brought by Tullow over the taxation of business interruption insurance proceeds.
According to a statement issued by the Minister of Finance, Dr Ato Forson, yesterday, the tribunal dismissed all claims brought by Tullow and upheld in full the assessment of US$393,091,993.70 by the Ghana Revenue Authority (GRA).
The tribunal further determined that the tax assessment did not breach the Petroleum Agreements between Ghana and Tullow, while finding that the penalty imposed was properly applied.
It also ruled that the assessment was not time-barred and that the enforcement action taken by the GRA was lawful.
Government hails victory
Dr Forson said the award vindicated the position Ghana had maintained throughout the dispute that companies operating in the country, regardless of their size, were subject to Ghanaian laws.
He acknowledged the work of the Office of the Attorney-General, the GRA and Ghana’s external legal counsel, Foley Hoag LLP, in defending the interests of the Republic.
The Finance Minister said the outcome had come at a critical time as Ghana and its Jubilee partners sought to maximise the prospects of the Jubilee and Tweneboa, Enyenra and Ntomme (TEN) fields.
He disclosed that, even before the tribunal delivered its award, the government had been in discussions with Tullow to resolve outstanding tax matters amicably.
Those discussions, he said, would continue to cover both the matter determined by the tribunal and separate proceedings concerning the disallowance of loan interest.
Revenue recovery
Dr Forson said the government would work closely with Tullow to give effect to the tribunal’s award in accordance with Ghanaian law.
He stressed, however, that implementation would take into account the continuity of operations in the Jubilee and TEN fields and Tullow’s capacity to sustain investment in the assets.
“Ghana’s laws provide the Ghana Revenue Authority with the means to determine the time and manner in which assessed liabilities are met,” the Minister said.
He said the government intended to implement the award in a manner that would secure revenues due to the Ghanaian people while preserving Tullow’s ability to continue operating and investing in Ghana as a going concern.
Tullow remains key
Despite the tax dispute, the government described Tullow as a vital partner to Ghana and the country’s largest petroleum producer.
Its operations in the Jubilee and TEN fields contribute to Ghana’s energy security and domestic gas supply, while supporting thousands of Ghanaian livelihoods, according to the statement.
Dr Forson said it was therefore in the national interest for the relationship between Ghana and Tullow to endure.
The government’s position suggests that the immediate focus following the arbitration award will be on balancing recovery of the assessed tax liability with the continued operation and investment of Tullow in Ghana’s upstream petroleum sector.
The separate dispute over the disallowance of loan interest remains unresolved, with government and Tullow expected to continue discussions on that matter.
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