Finance Minister Dr Cassiel Ato Forson announced that Ghana has emerged victorious in an international arbitration case brought by Tullow Ghana Limited regarding the taxation of business interruption insurance proceeds. The arbitral tribunal, constituted under the Rules of Arbitration of the International Chamber of Commerce (ICC), delivered its decision on Tuesday, September 29, 2026, ruling in favour of Ghana.
The tribunal dismissed all claims brought by Tullow and upheld in full the Ghana Revenue Authority’s (GRA) tax assessment of US$393,091,993.70. This assessment was found to be lawful, with the tribunal also ruling that the penalty imposed was properly applied and the assessment was not time-barred. Furthermore, the enforcement action taken by the GRA was deemed lawful.
Dr Ato Forson commended the Office of the Attorney-General, the GRA, and Ghana’s external legal counsel, Foley Hoag LLP, for successfully defending Ghana’s interests. He stated that the decision supports Ghana’s position that companies operating in the country must comply with Ghanaian laws, regardless of their size.
The ruling comes at a critical time as Ghana and its Jubilee partners work to maximise the potential of the Jubilee and TEN oil fields. Dr Ato Forson disclosed that the government had been engaging Tullow to find an amicable solution to outstanding tax matters before the tribunal delivered its decision. These discussions will continue, covering both the matter decided by the tribunal and a separate proceeding concerning the disallowance of loan interest.
Dr Ato Forson described Tullow as a vital partner to Ghana and the country’s largest petroleum producer. The company’s operations in the Jubilee and TEN fields significantly contribute to Ghana’s energy security, domestic gas supply, and the livelihoods of thousands of Ghanaians.
The government will work closely with Tullow to implement the tribunal’s decision in accordance with Ghanaian law. The government will also consider the need to maintain operations in the Jubilee and TEN fields, as well as Tullow’s capacity to continue investing in the fields. The objective is to secure revenues due to Ghanaians while ensuring Tullow remains a going concern and continues its operations and investments in the country.
The Finance Minister emphasised the importance of Tullow’s role in Ghana’s energy sector and the need for continued collaboration. The government’s approach will balance revenue collection with the need to support Tullow’s ongoing operations and investments, ensuring a stable and productive partnership between the company and the country.
Key points
- Ghana wins US$393m Tullow tax arbitration
- Tribunal rules in favour of Ghana Revenue Authority
- Government to work with Tullow to implement decision
