By Ishmeal 
Ghana has won an international tax dispute against Tullow Ghana Limited after an International Chamber of Commerce (ICC) tribunal dismissed the company’s claims.
The tribunal upheld a US$393.09 million tax assessment issued by the Ghana Revenue Authority (GRA). The ruling was delivered on September 29, 2026.
The case involves tax on business interruption insurance proceeds received by Tullow between 2016 and 2019.
Tribunal Upholds GRA Tax Assessment
The tribunal upheld the GRA’s assessment of US$393,091,993.70.
It found that the tax assessment did not breach Ghana’s Petroleum Agreements with Tullow. The tribunal also ruled that the penalty imposed by the GRA was properly applied.
The tribunal further found that the assessment was not time-barred and that the GRA acted lawfully when enforcing the tax.
The original assessment was issued in December 2022 and involved insurance proceeds received by Tullow between 2016 and 2019. The final amount includes penalties.
Government Welcomes the Decision
Finance Minister Dr Cassiel Ato Forson welcomed the tribunal’s decision and recognised the work of the Attorney-General’s Office, the GRA and Ghana’s external legal team.
The government said it intends to implement the tribunal’s decision in accordance with Ghanaian law.
At the same time, the government said it remains mindful of Tullow’s continued operations and investments in Ghana’s Jubilee and TEN oil fields.
Other Tax Matters Remain
The latest ruling does not end all tax-related discussions between Ghana and Tullow.
The government has indicated that discussions will continue on other outstanding tax matters, including an issue concerning the disallowance of loan interest.
Tullow remains an important operator in Ghana’s petroleum industry, particularly through its involvement in the Jubilee and TEN fields.
What Does the Ruling Mean for Ghana?
The decision is an important development in Ghana’s efforts to enforce tax obligations and protect government revenue.
For now, the international tribunal has upheld the GRA’s US$393.09 million assessment, while discussions on other outstanding matters between Ghana and Tullow continue.
The case will likely remain an important issue for Ghana’s petroleum and business sectors as both sides work through their remaining tax matters.
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