An arbitration tribunal constituted under the Rules of Arbitration of the International Chamber of Commerce (ICC) has ruled in favour of Ghana in a tax dispute involving Tullow Ghana Limited.
The tribunal, which delivered its award on Tuesday, September 29, 2026, dismissed all claims brought by Tullow over the taxation of business interruption insurance proceeds.
The ruling also upheld in full the Ghana Revenue Authority’s (GRA) tax assessment of US$393,091,993.70 against the oil company.
According to a statement from the Ministry of Finance, the tribunal found that the tax assessment did not breach the applicable Petroleum Agreements.
It further determined that the penalty imposed was properly applied, the assessment was not time-barred, and the GRA’s enforcement action was lawful.
The Ministry said the government acknowledges the work of the Office of the Attorney-General, the GRA and its external legal counsel, Foley Hoag LLP, in defending Ghana’s interests in the arbitration.
The government said the outcome reinforces its position that companies operating in Ghana, regardless of their size, are subject to the country’s laws.
The ruling comes as Ghana and the Jubilee partners continue efforts to maximise the prospects of the Jubilee and TEN oil fields.
The Ministry noted that prior to the tribunal’s award, government had been in discussions with Tullow to resolve outstanding tax matters amicably.
It said those discussions would continue, covering both the issues determined by the tribunal and separate proceedings concerning the disallowance of loan interest.
Despite the arbitration outcome, the government described Tullow as a “vital partner” and Ghana’s largest petroleum producer, noting that its operations in the Jubilee and TEN fields support the country’s energy security, domestic gas supply and thousands of livelihoods.
The government said it would therefore work closely with Tullow to give effect to the tribunal’s award in accordance with Ghanaian law.
It added that implementation would take into account the continuity of operations in the Jubilee and TEN fields and Tullow’s capacity to sustain the investments required in those fields.
The Ministry further stated that Ghanaian law gives the GRA the authority to determine the time and manner in which assessed liabilities are met.
Government said it intends to ensure that the award is implemented in a manner that secures revenues due to the Ghanaian people while allowing Tullow to continue operating and investing in Ghana as a going concern.
