Ghana has secured a major victory in an international tax arbitration case involving Tullow Ghana Limited, after an International Chamber of Commerce (ICC) Tribunal dismissed the company’s claims 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, bringing a significant development to the long-running tax dispute between the Ghanaian government and the oil producer.
ICC Tribunal Upholds Ghana Revenue Authority Tax Assessment
According to a statement issued by Finance Minister Dr Cassiel Ato Forson, the arbitration centred on the taxation of business interruption insurance proceeds received by Tullow Ghana.
The ICC Tribunal fully upheld the GRA’s tax assessment of US$393,091,993.70, rejecting Tullow Ghana’s claims challenging the assessment.
The Tribunal also ruled that the tax assessment did not violate the applicable Petroleum Agreements between Ghana and Tullow. It further determined that the penalty imposed by the Ghana Revenue Authority was properly applied and that the assessment was not barred by the applicable time limits.
In addition, the Tribunal concluded that the GRA’s enforcement action was lawful.
Ghana Government to Implement Arbitration Award
The ruling represents a major development in Ghana’s petroleum tax dispute with Tullow Ghana and provides support for the government’s position on the enforcement of tax obligations arising from business activities in the country.
The government is now preparing to implement the arbitration award in accordance with Ghanaian law.
Finance Minister Dr Cassiel Ato Forson praised the Office of the Attorney-General, Ghana Revenue Authority and Ghana’s external legal counsel, Foley Hoag LLP, for their efforts in defending Ghana’s position during the international arbitration proceedings.
He said the outcome reinforces the government’s position that companies operating in Ghana must comply with the country’s laws and tax regulations.
“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.
Government Reaffirms Ghana’s Tax Authority
The government said the ICC ruling confirms the validity of the GRA’s US$393 million tax assessment and recognises the authority of the revenue agency to enforce tax obligations arising from activities conducted in Ghana.
The decision is expected to have implications for Ghana’s petroleum sector, tax administration and government revenue, particularly regarding the taxation of companies operating under petroleum agreements.
Despite the favourable arbitration outcome, the government said it remains committed to reaching an amicable resolution to other outstanding tax matters involving Tullow Ghana.
Dr Ato Forson disclosed that Ghana government and Tullow Ghana had already begun discussions before the Tribunal delivered its final award.
The government has therefore indicated that it will continue engaging the oil producer while taking steps to implement the Tribunal’s decision under Ghana’s legal framework.
Source: newsthemegh.com