Ghana Wins Tullow Tax Arbitration as Tribunal Upholds US$393 Million Assessment

An arbitral tribunal has ruled in favour of Ghana in a tax dispute with Tullow Ghana Limited, upholding in full a Ghana Revenue Authority assessment of US$393,091,993.70.

In a press release issued on Wednesday, 30 September 2026, the Ministry of Finance said the tribunal, constituted under the Rules of Arbitration of the International Chamber of Commerce, dismissed all claims brought by Tullow over the taxation of business interruption insurance proceeds.

The tribunal found that the assessment did not breach the Petroleum Agreements, that the penalty was properly applied, that the assessment was not time-barred, and that the Ghana Revenue Authority’s enforcement action was lawful.

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

“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,” the statement said.

Government noted that the award has come at a critical time when Ghana and the Jubilee partners are working to maximise the prospects of the Jubilee and TEN fields.

Prior to the award, the government was in discussions with Tullow to resolve outstanding tax matters amicably. Those discussions will continue, covering both the matter determined by the tribunal and separate proceedings concerning the disallowance of loan interest, in the mutual interest of both parties.

Tullow remains a vital partner to Ghana and is the country’s largest petroleum producer. Its operations in the Jubilee and TEN fields support Ghana’s energy security, domestic gas supply and thousands of Ghanaian livelihoods. The government said it is in the national interest that the relationship endures.

The government will therefore work closely with Tullow to give effect to the award in accordance with Ghanaian law, while having due regard to the continuity of operations in the Jubilee and TEN fields and Tullow’s capacity to sustain the investments required in those fields.

Ghana’s laws provide the Ghana Revenue Authority with the means to determine the time and manner in which assessed liabilities are met. The government intends to ensure that the award is implemented in a way that secures the revenues due to the Ghanaian people while preserving Tullow’s ability to continue operating and investing in Ghana as a going concern.

The statement was signed by Dr Cassiel Ato Forson, MP, Minister for Finance