Ghana has won an international tax arbitration case brought by 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 (ICC) ruled in favour of Ghana and dismissed all claims brought by Tullow.
The tribunal also upheld in full the Ghana Revenue Authority’s (GRA) tax assessment of US$393,091,993.70 against the oil producer.
According to the Ministry of Finance, the tribunal found that the assessment did not breach the applicable Petroleum Agreements, the penalty imposed was properly applied, and the assessment was not time-barred.
It further held that the GRA’s enforcement action was lawful.
The Finance Minister, Dr Cassiel Ato Forson, in a statement on Wednesday, September 30, 2026, acknowledged the work of the Office of the Attorney-General, the GRA and Ghana’s external legal counsel, Foley Hoag LLP, in defending the interests of the state.
Dr Forson said the outcome affirmed the government’s position that companies operating in Ghana, regardless of their size, are subject to the country’s laws.
The ruling comes as the government and the Jubilee partners continue efforts to maximise the prospects of the Jubilee and TEN oil fields.
The minister said prior to the tribunal’s award, the government had been in discussions with Tullow to resolve outstanding tax matters amicably.
Those discussions, he said, would continue to cover the matter determined by the tribunal as well as separate proceedings concerning the disallowance of loan interest.
The government also said Tullow remains an important partner in Ghana’s petroleum sector and the country’s largest petroleum producer, with its operations in the Jubilee and TEN fields supporting energy security, domestic gas supply and thousands of livelihoods.
The Finance Ministry said the government would work closely with Tullow to give effect to the award in accordance with Ghanaian law, while having regard to the continuity of operations in the Jubilee and TEN fields and Tullow’s capacity to sustain the investments required in those fields.
It said Ghana’s laws empower the GRA to determine the time and manner in which assessed liabilities are met.
The government intends to ensure that the award is implemented in a manner that secures the revenues due to the Ghanaian people while preserving Tullow’s ability to continue operating and investing in Ghana.
