The Government of Ghana has won an international tax arbitration case against Tullow Ghana Limited over the taxation of business interruption insurance proceeds.
An arbitral tribunal constituted under the Rules of Arbitration of the International Chamber of Commerce delivered its award on Tuesday, September 29, 2026, ruling in favour of the Republic of Ghana.
According to the Ministry of Finance, the tribunal dismissed all claims brought by Tullow and upheld in full the Ghana Revenue Authority’s tax assessment of US$393,091,993.70.
The tribunal also found that the assessment did not breach the Petroleum Agreements, the penalty imposed was properly applied, the assessment was not time-barred, and the GRA’s enforcement action was lawful.
In a statement issued on Wednesday, September 30, Finance Minister Dr Cassiel Ato Forson commended the Office of the Attorney-General, the Ghana Revenue Authority and Ghana’s external legal counsel, Foley Hoag LLP, for their roles in defending the interests of the Republic.
Dr Forson said the ruling vindicates Ghana’s position that all companies operating in the country, regardless of their size, are subject to Ghanaian laws.
The Ministry noted that the ruling comes at a critical time as Ghana and its Jubilee partners seek to maximise the prospects of the Jubilee and TEN oil fields.
Government disclosed that prior to the tribunal’s decision, it had been engaged in discussions with Tullow to resolve outstanding tax matters amicably.
Those discussions, according to the Ministry, will continue and will cover both the matter determined by the tribunal and a separate proceeding concerning the disallowance of loan interest.
Despite the ruling, government described Tullow as a vital partner and Ghana’s largest petroleum producer, noting that its operations in the Jubilee and TEN fields contribute to the country’s energy security, domestic gas supply and thousands of Ghanaian livelihoods.
The government therefore said it would work closely with Tullow to implement the tribunal’s award in accordance with Ghanaian law, while taking into account the continuity of operations in the Jubilee and TEN fields and the company’s capacity to sustain investments in the fields.
Dr Forson said Ghana’s laws provide the GRA with the authority to determine the time and manner in which assessed liabilities are paid.
He said government intends to ensure that the 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.
By: Bernard Mensah
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