Ghana has won an international tax arbitration case against Tullow Ghana Limited after an International Chamber of Commerce (ICC) Tribunal rejected the oil company’s claims and upheld a US$393.09 million tax assessment issued by the Ghana Revenue Authority (GRA).
The ruling was delivered on Tuesday, September 29, 2026, by a tribunal established under the ICC Rules of Arbitration.
According to a statement from Finance Minister Dr Cassiel Ato Forson, the dispute involved the tax treatment of insurance proceeds Tullow received following a business interruption.
The Tribunal confirmed the GRA’s assessment of US$393,091,993.70 in full, dismissing Tullow’s objections to the tax liability.
It also ruled that the assessment was consistent with the relevant Petroleum Agreements and that the penalty imposed by the GRA was valid. The Tribunal further rejected Tullow’s argument that the assessment was made after the legally permitted period.
The Tribunal also affirmed that the GRA acted lawfully in seeking to enforce the tax assessment.
The decision represents a major development in the long-running tax dispute between the Ghanaian government and Tullow, one of the country’s key oil producers. Government is now expected to take steps to implement the award in accordance with Ghanaian law.
Finance Minister Dr Cassiel Ato Forson praised the Office of the Attorney-General, the GRA and Ghana’s external legal advisers, Foley Hoag LLP, for their work in presenting Ghana’s case during the arbitration.
He said the ruling supports the government’s position that all companies operating in Ghana must comply with the country’s laws.
“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 Ato Forson said.
Government said the ruling confirms both the validity of the GRA’s assessment and the authority of the tax agency to enforce tax obligations arising from business activities in Ghana.
However, the government indicated that it remains open to resolving other outstanding tax issues with Tullow through dialogue.
Dr Ato Forson also revealed that discussions between the government and Tullow had already begun before the Tribunal issued its decision.
