Ghana has secured a major victory in a long-running tax dispute with oil giant Tullow Ghana Limited, with an international arbitral tribunal upholding a tax assessment of US$393,091,993.70 against the company.
The Ministry of Finance announced the win in a press release dated 30th September 2026, signed by Finance Minister Dr. Cassiel Ato Forson.
According to the statement, an arbitral tribunal constituted under the Rules of Arbitration of the International Chamber of Commerce (ICC) yesterday delivered its award in proceedings brought against the Republic of Ghana by Tullow Ghana Limited over the taxation of business interruption insurance proceeds.
The Tribunal ruled entirely in favour of Ghana.
In a decisive award, the Tribunal dismissed all claims brought by Tullow Ghana Limited and upheld in full the Ghana Revenue Authority’s (GRA) tax assessment of US$393,091,993.70.
Crucially, the Tribunal found that the GRA’s assessment did not breach the Petroleum Agreements governing Tullow’s operations in Ghana.
It further ruled that the penalty applied by the GRA was properly applied, the assessment was not time-barred, and the GRA’s enforcement action was lawful.
Reacting to the victory, Finance Minister Dr. Cassiel Ato Forson acknowledged the work of the Office of the Attorney-General, the Ghana Revenue Authority and Ghana’s external legal counsel, Foley Hoag LLP, in defending the interests of the Republic.
He said the outcome vindicates the position Ghana has maintained throughout the dispute.
“This outcome vindicates the position Ghana has maintained throughout: that every company operating in this country, regardless of its size, is subject to the laws of Ghana,” Dr. Forson stated.
Government noted that the award has come at a critical time when Ghana and the Jubilee partners are working to maximize the prospects of the Jubilee and TEN Fields, the country’s two flagship oil fields.
The Finance Ministry disclosed that prior to the award, Government was in discussions with Tullow to resolve amicably all outstanding tax matters between the parties.
According to the statement, those discussions will continue, covering both the matter just determined by the Tribunal and separate proceedings concerning the disallowance of loan interest. Government says the discussions are ongoing and would be resolved in the mutual interest of both parties.
Despite the legal victory, Government stressed that Tullow remains a vital partner to Ghana.
The Ministry described Tullow as the country’s largest petroleum producer, whose operations in the Jubilee and TEN fields support Ghana’s energy security, domestic gas supply and thousands of Ghanaian livelihoods.
“It is in the national interest that this relationship endures,” the Minister said.
On implementation of the award, Government said it will work closely with Tullow to give effect to the award in accordance with Ghanaian law.
In doing so, Government will have due regard to the continuity of operations in the Jubilee and TEN fields and Tullow’s capacity to sustain the investments required in those fields.
The Ministry added that Ghana’s laws provide the Ghana Revenue Authority with the means to determine the time and manner in which assessed liabilities are met.
Government intends to ensure that the award is implemented in a way that secures the revenues due to the Ghanaian people while preserving Tullow’s ability to continue operating and investing in Ghana as a going concern.
The $393 million victory is seen as a major boost to Ghana’s domestic revenue mobilization drive and a strong precedent for enforcement of tax compliance in the extractive sector.
