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Energy and Extractives

Ghana Wins US$393m Tax Arbitration Against Tullow Oil

Ghana has won a US$393.09 million tax arbitration against Tullow Ghana Limited, with an international tribunal upholding the GRA's assessment on business interruption insurance proceeds.

Prince Agyapong
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Wednesday, 30 September 2026
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Ghana Wins US$393m Tax Arbitration Against Tullow Oil

Ghana has secured a favourable ruling in a US$393.09 million tax arbitration against Tullow Ghana Limited, after an international tribunal upheld the Ghana Revenue Authority's assessment involving business interruption insurance proceeds.

The tribunal, constituted under the International Chamber of Commerce's arbitration rules, delivered its decision on Tuesday, September 29, 2026.

Finance Minister Dr Cassiel Ato Forson confirmed the outcome in a statement issued on Wednesday, September 30, describing the decision as an affirmation of Ghana's authority to enforce its tax laws.

Tribunal Dismisses Tullow's Claims

According to the Finance Minister, the tribunal dismissed all claims brought by Tullow and upheld the GRA's assessment of US$393,091,993.70.

The tribunal found that the assessment did not breach existing petroleum agreements, was not time-barred and included a properly applied penalty.

It also upheld the legality of the GRA's enforcement action.

Dr Forson maintained that “every company operating in this country, regardless of its size, is subject to the laws of Ghana.”

He acknowledged the contributions of the Attorney-General's Office, the GRA and international legal firm Foley Hoag LLP in defending Ghana's position.

Government to Continue Negotiations

Despite the ruling, government says discussions with Tullow will continue to resolve outstanding tax matters.

These include arrangements concerning the tribunal's award and separate proceedings relating to the disallowance of loan interest.

Dr Forson indicated that government would pursue the revenue due while considering Tullow's financial capacity and continued investment in Ghana.

The Finance Minister emphasised that Tullow remains an important petroleum partner, with operations supporting production, domestic gas supply and employment.

Government intends to work with the company to implement the award without undermining operations at the Jubilee and TEN fields.

The GRA will determine the appropriate payment arrangements under Ghanaian law.

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