Ghana wins Tullow Tax Arbitration, as tribunal upholds US$393m GRA assessment

Ghana has won its tax arbitration case against Tullow Ghana Limited, with an international tribunal upholding a tax assessment of US$393,091,993.70 raised by the Ghana Revenue Authority (GRA), according to the Ministry of Finance.

In a press release issued in Accra on Wednesday, 30th September 2026, the Ministry said a tribunal constituted under the Rules of Arbitration of the International Chamber of Commerce delivered its award on Tuesday. The case concerned the taxation of business interruption insurance proceeds.

The Ministry said the tribunal dismissed all of Tullow’s claims and upheld the GRA’s assessment in full.

It 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 GRA’s enforcement action was lawful.

Finance Minister Dr Cassiel Ato Forson, who signed the statement, acknowledged the work of the Office of the Attorney-General, the GRA and Ghana’s external counsel, Foley Hoag LLP.

He said the outcome vindicates Ghana’s position that every company operating in the country, regardless of its size, is subject to the laws of Ghana.

The Government said the award comes at a critical time, as Ghana and the Jubilee partners work to maximise the prospects of the Jubilee and TEN fields.

It added that it had been in discussions with Tullow before the award to resolve outstanding tax matters amicably.

Those talks will continue and will cover both the matter decided by the tribunal and separate proceedings over the disallowance of loan interest.

The Ministry described Tullow as a vital partner and Ghana’s largest petroleum producer, noting that its operations support the country’s energy security, domestic gas supply and thousands of livelihoods.

It said Government will work with Tullow to give effect to the award in accordance with Ghanaian law, with due regard to the continuity of operations and the company’s capacity to sustain investment.

The Ministry noted that Ghana’s laws give the GRA the means to determine the time and manner in which assessed liabilities are met.

Government intends to implement the award in a way that secures revenue for the Ghanaian people while preserving Tullow’s ability to keep operating and investing in Ghana as a going concern.