Ghana has won an international arbitration case against Tullow Oil, with a tribunal under the International Chamber of Commerce (ICC) Rules upholding in full the Ghana Revenue Authority’s (GRA) tax assessment of US$393,091,993.70. Finance Minister Dr Cassiel Ato Forson announced the outcome in a statement on Wednesday, September 30, 2026.
“The Tribunal ruled in favour of Ghana. It dismissed all claims brought by Tullow and upheld in full the Ghana Revenue Authority’s tax assessment,” the minister said.
The dispute concerned the taxation of proceeds Tullow received under its corporate Business Interruption insurance policy between 2016 and 2019. Tullow had argued that the assessment breached the protections in its Petroleum Agreements with Ghana.
Tullow Oil plc confirmed the ruling in its own market statement the same day, saying it was disappointed with the decision.
ICC tribunal upholds US$393m Tullow tax assessment
According to the Ministry of Finance, the arbitral tribunal dismissed every claim Tullow brought against Ghana.
The tribunal found that the assessment did not breach the Petroleum Agreements, that the penalty was properly applied, that the assessment was not time-barred, and that the GRA’s enforcement action was lawful.
Ghana was represented by the Office of the Attorney-General and the GRA, supported by external counsel Foley Hoag LLP.
Ghana Wins US$393m Tullow Tax Arbitration as ICC Tribunal Upholds GRA Assessment [SHORT VIDEO]
How the Tullow tax figure breaks down
Tullow’s statement puts the underlying corporate income tax assessment at US$196.5 million, with a 100% penalty on top. Together, they make up the roughly US$393 million figure cited by the government.
- Corporate income tax assessment: US$196.5 million
- Penalty: 100% of the assessment
- Total upheld (per Finance Ministry): US$393,091,993.70
- Tax years covered: 2016 to 2019
- Subject of tax: Business Interruption insurance proceeds
Tullow said the tribunal ruled that the US$196.5 million assessment does not breach its Petroleum Agreements, and that the 100% penalty falls outside the scope of the contractual protections in those agreements.
Background to the Ghana–Tullow tax dispute
Tullow Ghana Limited referred two disputed GRA tax claims to ICC arbitration in London in early 2023. One related to the Business Interruption insurance proceeds; the other concerned the GRA’s disallowance of loan interest deductions worth US$190.5 million for 2010 to 2020.
The latest ruling reverses the direction of an earlier arbitration. In January 2025, an ICC tribunal ruled in Tullow’s favour in a separate US$320 million dispute over Branch Profits Remittance Tax.
What Ato Forson said about the Tullow ruling
Dr Ato Forson said the outcome sends a clear message about compliance with Ghana’s tax laws.
“Every company operating in this country, regardless of its size, is subject to the laws of Ghana,” he stated.
The government said it had engaged Tullow in discussions before the tribunal’s decision in an effort to reach an amicable resolution.
What it means for Ghana’s revenue and the oil sector
The ruling confirms the GRA’s right to collect the full assessed amount, a significant sum for a government that has faced scrutiny over revenue performance, including in the Minority’s reaction to the mid-year budget review.
The government stressed that Tullow remains Ghana’s largest petroleum producer and a key partner in the Jubilee and TEN oil fields. It said the award will be implemented in accordance with Ghanaian law while keeping Tullow’s operations in those fields running.
For Tullow, the decision adds a large liability. The company has not said how or when it will settle the amount.
What happens next for Tullow and Ghana
Tullow said it “will now consider next steps after further engagement with the Government of Ghana,” adding that an update will be provided in due course.
The government said talks with Tullow will continue on both the tribunal’s decision and the separate dispute over disallowed loan interest deductions.
Key details at a glance
- Ghana wins ICC arbitration against Tullow Oil, announced September 30, 2026.
- Tribunal upheld the GRA’s assessment of US$393,091,993.70 in full.
- Amount comprises a US$196.5m corporate income tax assessment plus a 100% penalty.
- Tax relates to Business Interruption insurance proceeds received from 2016 to 2019.
- Tribunal found the assessment lawful, not time-barred, and not in breach of the Petroleum Agreements.
- Tullow says it is disappointed and will consider next steps after talks with government.
- A separate US$190.5m loan interest deduction dispute remains under discussion.
FAQs
How much did Ghana win in the Tullow tax arbitration?
The tribunal upheld the GRA’s assessment of US$393,091,993.70, made up of a US$196.5 million tax assessment and a 100% penalty.
What was the Tullow tax dispute with Ghana about?
It concerned corporate income tax on proceeds Tullow received under its Business Interruption insurance policy between 2016 and 2019. Tullow argued the assessment breached its Petroleum Agreements.
Will Tullow appeal the ICC ruling?
Tullow has not announced an appeal. It said it will consider next steps after further engagement with the Government of Ghana.
The ICC tribunal’s decision hands Ghana a major win in its long-running tax fight with Tullow Oil, upholding a US$393 million GRA assessment in full. With Tullow weighing its options and talks continuing on a second tax dispute, attention now turns to how and when the award is paid, and how both sides protect production at Jubilee and TEN.
