Ghana has won an international tax arbitration case against Tullow Ghana Limited over the taxation of business interruption insurance proceeds.
The Ministry of Finance said 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 the Republic.
According to the Ministry, the tribunal dismissed all claims brought by Tullow and upheld in full the Ghana Revenue Authority’s tax assessment of US$393,091,993.70.
It said the tribunal also found that the tax assessment did not breach Ghana’s Petroleum Agreements, the penalty imposed was properly applied, and the assessment was not time-barred.
The tribunal further ruled that the enforcement action taken by the Ghana Revenue Authority was lawful, the Ministry said.
Finance Minister Dr Cassiel Ato Forson acknowledged the work of the Attorney-General’s Office, the Ghana Revenue Authority and Ghana’s external legal counsel, Foley Hoag LLP, in defending Ghana’s position.
He said the outcome supports the government’s position that all companies operating in Ghana, regardless of their size, are subject to the country’s laws.
The Ministry, however, said the government had been in discussions with Tullow before the tribunal’s decision to find an amicable solution to outstanding tax matters between the two parties.
It said those discussions would continue to cover both the matter decided by the tribunal and a separate case involving the disallowance of loan interest.
The government described Tullow as a vital partner and Ghana’s largest petroleum producer, noting that its operations in the Jubilee and TEN fields contribute to the country’s energy security, domestic gas supply and thousands of jobs.
The Ministry said the government would work closely with Tullow to implement the tribunal’s decision in accordance with Ghanaian law.
It added that the government would consider the need to maintain operations in the Jubilee and TEN fields while ensuring that Tullow can continue making the investments needed to operate in Ghana.
Dr Forson said the government’s approach would be to secure the revenues due to the Ghanaian people while preserving Tullow’s ability to continue operating and investing in the country as a going concern.
By: Jacob Aggrey
