Ghana wins US$393m tax dispute against Tullow Ghana Limited

Tullow Ghana Limited has lost a major tax dispute with Ghana after an international arbitration tribunal rejected the company’s challenge to a US$393.09 million assessment by the Ghana Revenue Authority (GRA).

The ruling, delivered on Tuesday, September 29, 2026, clears the way for Ghana to enforce the tax assessment, which relates to business interruption insurance proceeds received by Tullow.

The case was heard under the arbitration rules of the International Chamber of Commerce (ICC). The tribunal dismissed all of Tullow’s claims and upheld the GRA’s assessment of US$393,091,993.70.

The tribunal also found that the assessment complied with the relevant Petroleum Agreements. It further upheld the penalty imposed by the GRA and determined that the tax assessment was not time-barred.

The tribunal also ruled that the GRA acted lawfully when it took steps to enforce the assessment.

The Ministry of Finance announced the outcome in a statement on Wednesday, September 30, describing the decision as a confirmation of Ghana’s position that businesses operating in the country are subject to its laws.

“This outcome 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,” the Ministry said.

The government praised the Office of the Attorney-General, the GRA and Ghana’s external legal advisers, Foley Hoag LLP, for their role in the arbitration.

Despite the ruling, government says it wants Tullow to remain a key player in Ghana’s petroleum sector.

Tullow is the country’s largest petroleum producer and operates in the Jubilee and TEN fields. Its operations contribute to Ghana’s energy supply, domestic gas production and employment.

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“Tullow remains a vital partner to Ghana and is the country’s largest petroleum producer. Its operations in the Jubilee and TEN fields support Ghana’s energy security, domestic gas supply and thousands of Ghanaian livelihoods. It is in the national interest that this relationship endures,” the Ministry said.

The government also disclosed that it had been engaging Tullow before the tribunal issued its decision. The discussions were aimed at finding an amicable resolution to outstanding tax issues.

Those engagements will continue, according to the Ministry, covering both the issues addressed by the tribunal and a separate dispute over the disallowance of loan interest.

Ghana also intends to work with Tullow on the implementation of the arbitration award. The Ministry said the process will take Ghanaian law into account while considering Tullow’s continued operations and future investment in the Jubilee and TEN fields.

Under Ghanaian law, the GRA has the authority to determine when and how assessed tax liabilities are paid.

The government said it would therefore seek to recover the money owed to the state while ensuring that Tullow remains able to operate and invest in Ghana.

“The Government intends to ensure that the award is implemented in a way that secures the revenues due to the Ghanaian people while preserving Tullow’s ability to continue operating and investing in Ghana as a GOING CONCERN,” the Ministry said.

The dispute began over the tax treatment of insurance proceeds Tullow received after business interruptions. The company challenged the resulting GRA assessment through international arbitration.

With the tribunal now dismissing Tullow’s claims, Ghana’s US$393.09 million tax assessment has been upheld in full.

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