Ghana has secured a major victory in an arbitration case brought by Tullow Ghana Limited over the taxation of business interruption insurance proceeds, with an international tribunal dismissing all claims brought by the oil company.
An arbitral tribunal constituted under the Rules of Arbitration of the International Chamber of Commerce (ICC) has ruled in favour of Ghana and upheld in full a tax assessment of US$393,091,993.70 imposed by the Ghana Revenue Authority (GRA).
According to a statement issued by the Minister for Finance, Dr Cassiel Ato Forson, on Wednesday, September 30, 2026, the tribunal rejected Tullow’s claims and found that the GRA’s assessment was lawful.
The tribunal further determined that the assessment did not breach Ghana’s Petroleum Agreements, the applicable penalty had been properly imposed, and the tax assessment was not time-barred.
The Finance Minister commended the Office of the Attorney-General, the Ghana Revenue Authority and Ghana’s external legal counsel, Foley Hoag LLP, for their work in defending the interests of the Republic.
Dr Ato Forson said the outcome vindicates Ghana’s long-standing position that all companies operating in the country, regardless of their size, are subject to Ghanaian laws.
Government to continue talks with Tullow
Despite the arbitration victory, the government says it intends to continue discussions with Tullow to resolve outstanding tax matters amicably.
According to the statement, prior to the tribunal’s decision, the government and Tullow are already engaged in discussions aimed at resolving the tax issues between the two parties.
Those discussions, the Minister said, will continue to cover both the matters determined by the tribunal and separate proceedings concerning the disallowance of loan interest.
The government says the ongoing engagements are intended to reach a resolution that serves the mutual interests of both parties.
Tullow remains key partner
The Finance Minister stressed that Tullow remains an important partner to Ghana and the country’s largest petroleum producer.
He noted that Tullow’s operations in the Jubilee and TEN fields contribute to Ghana’s energy security, domestic gas supply and the livelihoods of thousands of Ghanaians.
Dr Ato Forson said it is therefore in the national interest for the relationship between Ghana and Tullow to continue.
The government, he said, will work closely with Tullow to give effect to the tribunal’s award in accordance with Ghanaian law, while taking into consideration the continuity of operations in the Jubilee and TEN fields and Tullow’s capacity to sustain the investments required in those fields.
Government seeks balance between revenue and investment
The Minister explained that Ghana’s laws empower the Ghana Revenue Authority to determine the time and manner in which assessed liabilities are met.
He said the government intends to ensure that the arbitration award is implemented in a manner that secures revenues due to the Ghanaian people while preserving Tullow’s ability to continue operating and investing in Ghana as a going concern.
The arbitration ruling therefore marks a significant development in the tax dispute between Ghana and Tullow, while the government indicates that engagement with the oil producer will continue on the outstanding matters.
