Ghana has secured a major victory in its tax dispute with Tullow Ghana Limited after an arbitral tribunal ruled in favour of the Republic and upheld a US$393.09 million tax assessment issued by the Ghana Revenue Authority (GRA).
The tribunal, constituted under the Rules of Arbitration of the International Chamber of Commerce (ICC), delivered its award on Tuesday, September 29, 2026, dismissing all claims brought by Tullow over the taxation of business interruption insurance proceeds.
The decision means the GRA’s assessment of US$393,091,993.70 remains valid.
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According to Finance Minister Dr Cassiel Ato Forson, the tribunal found that the tax assessment did not breach the applicable Petroleum Agreements.
The tribunal also determined that the penalty imposed was properly applied, the assessment was not time-barred, and the GRA’s enforcement action was lawful.
The outcome represents a significant development in Ghana’s efforts to enforce its tax laws and secure revenue from the country’s petroleum sector.
Dr Ato Forson commended the Office of the Attorney-General, the GRA and Ghana’s external legal counsel, Foley Hoag LLP, for their roles in defending the interests of the Republic.
He said the ruling vindicates Ghana’s position that companies operating in the country, irrespective of their size, are subject to Ghanaian laws.
Despite the tribunal’s decision, the government said it remains committed to maintaining a constructive relationship with Tullow, describing the company as a vital partner in Ghana’s petroleum industry.
Before the tribunal’s award, the government and Tullow had been engaged in discussions aimed at resolving outstanding tax matters amicably.
According to Dr Ato Forson, those discussions will continue and will cover both the matter determined by the tribunal and a separate dispute concerning the disallowance of loan interest.
He said the outstanding issues would be addressed in the mutual interest of both parties.
Tullow remains Ghana’s largest petroleum producer, with operations in the Jubilee and TEN fields.
The government said the company’s activities contribute to Ghana’s energy security, domestic gas supply and the livelihoods of thousands of Ghanaians.
The government said it intends to work closely with Tullow to give effect to the tribunal’s award in accordance with Ghanaian law.
At the same time, authorities said consideration would be given to the continuity of operations in the Jubilee and TEN fields and Tullow’s ability to sustain investment in those assets.
Dr Ato Forson said Ghana’s laws give the GRA the authority to determine the time and manner in which assessed tax liabilities are paid.
According to him, the government would ensure that the revenues due to the Ghanaian people are secured while preserving Tullow’s capacity to continue operating and investing in Ghana as a going concern.