An International Chamber of Commerce (ICC) Tribunal has dismissed claims brought by Tullow Ghana Limited in a tax arbitration dispute with Ghana and upheld a US$393.09 million tax assessment issued by the Ghana Revenue Authority (GRA).
The decision was delivered on Tuesday, September 29, 2026, by a tribunal constituted under the ICC Rules of Arbitration.
According to a statement from Finance Minister Dr. Cassiel Ato Forson, the dispute centred on the taxation of insurance proceeds received by Tullow in connection with business interruption. The Tribunal upheld the GRA’s assessment of US$393,091,993.70 and rejected Tullow’s claims challenging the assessment.
It also ruled that the tax assessment did not breach the applicable Petroleum Agreements and that the penalty imposed by the GRA was properly applied.
The Tribunal further determined that the assessment was not time-barred and that the GRA’s enforcement action was lawful.
The ruling marks a significant development in the long-running tax dispute between the government and Tullow Ghana, one of Ghana’s major petroleum producers.
The government said it will take steps to implement the award in accordance with Ghanaian law.
Dr. Ato Forson commended the Office of the Attorney-General, the GRA and Ghana’s external legal counsel, Foley Hoag LLP, for their roles in defending Ghana’s position during the arbitration. He said the decision affirmed the government’s position that companies operating in Ghana are subject to 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.
The government said the ruling confirms the validity of the GRA’s assessment and its authority to enforce tax obligations arising from activities in Ghana.
Despite the outcome of the arbitration, Dr. Ato Forson said the government remained committed to resolving outstanding tax matters with Tullow through amicable discussions.
He disclosed that engagements between the government and Tullow had been ongoing before the Tribunal delivered its decision.