The Government of Ghana has secured a major victory in its tax dispute with Tullow Ghana Limited after an international arbitration tribunal dismissed all claims brought by the oil producer over the taxation of business interruption insurance proceeds.
In a statement on Wednesday, September 30, 2026, the Ministry of Finance said the tribunal, constituted under the Rules of Arbitration of the International Chamber of Commerce (ICC), ruled in favour of Ghana and upheld in full the Ghana Revenue Authority’s (GRA) tax assessment of US$393,091,993.70 against Tullow.
The tribunal found that the tax assessment did not breach the applicable Petroleum Agreements, the penalty was properly applied, the assessment was not time-barred, and the GRA’s enforcement action was lawful.
The Finance Ministry said the decision reinforces the government’s position that all companies operating in Ghana are subject to the country’s 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 statement said.
The government commended the Office of the Attorney-General, the GRA and Ghana’s external legal counsel, Folely Hoag LLP, for defending the interests of the Republic.
The ruling comes at a time when Ghana and Tullow’s Jubilee partners are working to maximise production from the Jubilee and TEN oil fields.
According to the government, discussions with Tullow had already been underway before the arbitration award to resolve the outstanding tax matters amicably.
It said those discussions would continue to cover both the issues determined by the tribunal and separate proceedings concerning the disallowance of loan interest.
Despite the tax dispute, the government stressed the importance of Tullow’s continued operations in Ghana.
“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 statement said.
The government said it would work with Tullow to implement the arbitration award in accordance with Ghanaian law while taking into account the continuity of operations and the company’s ability to sustain investment in the Jubilee and TEN fields.
It also noted that Ghanaian law gives the GRA the authority to determine the time and manner in which assessed liabilities are paid.
“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 statement said.
The dispute concerned the taxation of business interruption insurance proceeds received by Tullow. The matter was referred to an international arbitration tribunal constituted under the ICC Rules.
The latest ruling dismisses Tullow’s claims and upholds the GRA’s US$393.09 million tax assessment, marking a significant victory for Ghana in the long-running tax dispute.
