Ghana has won an international tax arbitration case brought by Tullow Ghana Limited over the taxation of business interruption insurance proceeds, with the tribunal upholding a Ghana Revenue Authority (GRA) assessment of US$393,091,993.70.
According to a statement issued by Finance Minister Dr Cassiel Ato Forson, 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 Ghana.
The Tribunal dismissed all claims brought by Tullow and upheld the GRA’s tax assessment in full.
It 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.
Dr Forson said the outcome supports Ghana’s position that companies operating in the country are subject to Ghanaian laws.
He acknowledged the work of the Office of the Attorney-General, the GRA and Ghana’s external legal counsel, Foley Hoag LLP, in defending the case.
The Finance Minister said the government had been engaged in discussions with Tullow before the award to resolve outstanding tax matters amicably. Those discussions, he said, will continue to cover both the arbitration matter and separate proceedings concerning the disallowance of loan interest.
Dr Forson said Tullow remains Ghana’s largest petroleum producer and that its operations in the Jubilee and TEN fields contribute to the country’s energy security, domestic gas supply and livelihoods.
He said the government would work with Tullow to implement the award in accordance with Ghanaian law while having regard to the continuity of operations in the Jubilee and TEN fields and the company’s capacity to sustain investment.
The government, he added, intends to ensure that the tax liabilities due to the state are secured while preserving Tullow’s ability to continue operating and investing in Ghana as a going concern.
