Ghana Wins $393m Tax Dispute Against Tullow Ghana
Ghana has won a major international tax dispute against Tullow Ghana Limited after an arbitral tribunal dismissed claims brought by the oil company and upheld a tax assessment of more than US$393 million by the Ghana Revenue Authority (GRA).
The dispute involved the taxation of proceeds Tullow Ghana received from business interruption insurance.
In a statement issued on Wednesday, September 30, 2026, Finance Minister Dr Cassiel Ato Forson said the tribunal, constituted under the International Chamber of Commerce (ICC) Rules of Arbitration, rejected all the claims presented by Tullow.
According to Dr Forson, the tribunal determined that the GRA’s tax assessment did not breach the applicable Petroleum Agreements.
The tribunal also upheld the penalty imposed on Tullow, ruling that the assessment was not time-barred.
It further found that the GRA acted lawfully in enforcing the tax assessment.
“The Tribunal ruled in favour of Ghana,” Dr Forson stated.
The Finance Minister said the outcome strengthens the government’s position that all companies operating in Ghana are required to comply with the country’s laws, irrespective of their size or influence.
He said the decision “vindicates the position Ghana has maintained throughout: that every company operating in this country, regardless of its size, is subject to the laws of Ghana.”
Dr Forson commended the Office of the Attorney-General, the Ghana Revenue Authority and Ghana’s external legal counsel, Foley Hoag LLP, for their work in representing the interests of the Republic throughout the arbitration proceedings.
He said the government would now take the necessary steps to implement the tribunal’s award in accordance with Ghanaian law.
However, Dr Forson stressed that the government would also ensure that Tullow Ghana maintains the capacity to continue its operations and investments in Ghana’s Jubilee and TEN oil fields.
The latest ruling comes amid broader tax disagreements between Tullow Ghana and the Ghana Revenue Authority.
Tullow had previously disclosed that the tax assessment relating to business interruption insurance arose from proceeds it received during the 2016 to 2019 financial years.
The company subsequently challenged the assessment through arbitration under the rules of the International Chamber of Commerce.
The tribunal’s decision has now dismissed Tullow’s claims and upheld the GRA’s assessment, bringing the international arbitration to a conclusion in favour of Ghana.
