Ghana wins $393m Tullow tax arbitration as tribunal dismisses all claims

Ghana has secured a major legal victory against oil giant Tullow Ghana Limited after an international arbitration tribunal dismissed all claims brought by the company over the taxation of business interruption insurance proceeds.

The arbitration tribunal, constituted under the Rules of Arbitration of the International Chamber of Commerce (ICC), delivered its award on Tuesday, September 29, 2026, ruling in favour of the Republic of Ghana.

According to a statement issued by the Ministry of Finance on Wednesday, September 30, the tribunal upheld in full the Ghana Revenue Authority’s (GRA) tax assessment of US$393,091,993.70 against Tullow.

The tribunal further found that the tax assessment did not breach Ghana’s Petroleum Agreements and determined that the penalty imposed was properly applied.

It also ruled that the assessment was not time-barred and that the enforcement action taken by the GRA was lawful.

Ghana secures major tax victory

The Finance Ministry said the outcome vindicates the position Ghana has maintained throughout the dispute — that every company operating in the country, regardless of its size, remains subject to Ghanaian laws.

Finance Minister Dr Cassiel Ato Forson commended the work of the Office of the Attorney-General, the Ghana Revenue Authority and Ghana’s external legal counsel, Folely Hoag LLP, for their efforts in defending the interests of the Republic.

The ruling comes at a significant time for Ghana’s oil sector, as the government and its Jubilee partners work to maximise the prospects of the Jubilee and TEN oil fields.

Government moves to implement award

The government has indicated that it will work closely with Tullow to give effect to the tribunal’s award in accordance with Ghanaian law.

However, the Ministry stressed that implementation would take into consideration the continuity of operations in the Jubilee and TEN fields, as well as Tullow’s capacity to sustain the investments required in those fields.

The government also noted that Ghanaian law gives the GRA the authority to determine the timing and manner in which assessed tax liabilities are settled.

According to the Ministry, its objective is to ensure that the award secures the revenues due to the Ghanaian people while preserving Tullow’s ability to continue operating and investing in Ghana.

Talks with Tullow to continue

The Finance Ministry disclosed that prior to the tribunal’s decision, the government had been engaged in discussions with Tullow to find an amicable resolution to outstanding tax matters between the two parties.

Those discussions, the Ministry said, will continue and will cover both the matter determined by the tribunal and separate proceedings concerning the disallowance of loan interest.

The government expressed confidence that the discussions would ultimately be resolved in the mutual interest of both parties.

Despite the legal dispute, the Ministry described Tullow as a vital partner to Ghana and the country’s largest petroleum producer.

It 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.

The government therefore emphasised that it remains in the national interest for the relationship between Ghana and Tullow to endure, even as the latest arbitration award is implemented.