Ghana wins Tullow tax dispute as ICC tribunal upholds US$393m GRA assessment

• An ICC arbitration tribunal has ruled in favour of Ghana in its tax dispute with Tullow.

• The tribunal upheld the GRA’s US$393.09 million tax assessment against Tullow.

• Government says talks with Tullow will continue as it works to implement the award while protecting oil operations.

The tribunal, constituted under the Rules of Arbitration of the International Chamber of Commerce, delivered its award on Tuesday, September 29, 2026, in a dispute over the taxation of business interruption insurance proceeds.

In a statement issued by the Ministry of Finance on Wednesday, September 30, Finance Minister Dr Cassiel Ato Forson said the tribunal ruled in favour of Ghana and upheld the GRA’s assessment in full.

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The tribunal found that the assessment did not breach the Petroleum Agreements, the penalty was properly applied, the assessment was not time-barred, and the GRA’s enforcement action was lawful.

Dr Forson commended the Office of the Attorney-General, the GRA and Ghana’s external legal counsel, Foley Hoag LLP, for their role in defending the country’s position.

“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,” he said.

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

According to the Ministry, the discussions cover both the matter determined by the tribunal and separate proceedings concerning the disallowance of loan interest.

“Tullow remains a vital partner to Ghana and is the country's largest petroleum producer,” Dr Forson said, noting that the company’s operations in the Jubilee and TEN fields support Ghana’s energy security, domestic gas supply and thousands of livelihoods.

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He said government would work closely with Tullow to implement the award in accordance with Ghanaian law while taking into account the continuity of operations in the Jubilee and TEN fields.

The government also said it would ensure that the revenues due to the state are secured without undermining Tullow’s ability to continue operating and investing in Ghana.

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“Ghana's laws provide the Ghana Revenue Authority with the means to determine the time and manner in which assessed liabilities are met,” Dr Forson said.

He added that the government would implement the award in a manner that protects Ghana’s revenue while preserving Tullow’s ability to continue operating and investing in the country as a going concern.