Ghana has won a major international tax arbitration case involving Tullow Ghana Limited, with an International Chamber of Commerce (ICC) Tribunal dismissing the oil producer’s challenge to a US$393.09 million tax assessment imposed by the Ghana Revenue Authority (GRA).
The ruling, delivered on Tuesday, September 29, 2026, found that the GRA’s assessment relating to tax on Tullow’s business interruption insurance proceeds was valid and enforceable.
The Tribunal upheld the full assessment of US$393,091,993.70, rejecting Tullow’s claims that the tax demand was inconsistent with its petroleum agreements with Ghana.
It also ruled that the penalty imposed by the GRA was properly applied and that the assessment was not barred by the applicable statutory time limit.
The Tribunal further determined that the GRA acted lawfully in seeking to enforce the assessment.
In a statement, Finance Minister Dr Cassiel Ato Forson said the government would proceed to implement the award in accordance with Ghanaian law.
The dispute arose from the tax treatment of insurance proceeds received by Tullow following business interruption, with the company challenging the GRA’s assessment through international arbitration.
The decision now clears a major legal hurdle for Ghana in its effort to enforce the tax claim against the petroleum producer.
Dr Ato Forson commended the Office of the Attorney-General, the GRA and Ghana’s external legal counsel, Foley Hoag LLP, for defending the country’s position during the arbitration proceedings.
He said the ruling affirmed the principle that companies operating in Ghana must comply with the country’s tax 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,” he said.
The government is expected to take the necessary steps under Ghanaian law to give effect to the Tribunal’s decision.
