Ghana has secured a major victory in its international tax arbitration dispute with Tullow Ghana Limited after an International Chamber of Commerce (ICC) Tribunal dismissed the oil producer’s claims and upheld a US$393.09 million tax assessment issued by the Ghana Revenue Authority (GRA). The decision was delivered on Tuesday, September 29, 2026, by a tribunal constituted under the ICC Rules of Arbitration.
According to a statement from Finance Minister Dr Cassiel Ato Forson, the dispute focused on the tax treatment of business interruption insurance proceeds received by Tullow.
The Tribunal upheld the GRA’s assessment in full, amounting to US$393,091,993.70, and rejected Tullow’s challenge to the assessment. It also ruled that the assessment did not violate the applicable Petroleum Agreements, that the penalty imposed by the GRA was valid, and that the assessment had not become time-barred. The Tribunal further determined that the GRA’s enforcement actions were lawful.
The ruling represents a significant development in the long-running tax dispute between the Ghanaian government and Tullow, one of the country’s major petroleum producers. The government is now expected to take steps to implement the award in accordance with Ghanaian law.
Dr 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 Ghana’s position during the arbitration. He said the ruling reinforces the government’s position that all companies operating in Ghana, regardless of their size, 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,” Dr Ato Forson said. The government said the ruling confirms both the validity of the GRA’s tax assessment and its authority to enforce tax obligations arising from activities conducted in Ghana.
Despite the favourable outcome, however, the government said it remains committed to resolving any outstanding tax matters with Tullow through an amicable process. Dr Ato Forson disclosed that discussions between the government and Tullow were already underway before the Tribunal issued its award.
