Gov’t, Tullow agree roadmap to resolve $393m tax dispute
The government and Tullow Ghana Limited have reached an agreement on a roadmap to resolve a US$393.09 million tax liability confirmed by an international arbitration tribunal.
President John Dramani Mahama disclosed this at the 2026 Local Content Conference and Exhibition in Takoradi, stating that both parties had arrived at a mutually acceptable arrangement following the tribunal’s decision.
The agreement comes after a September 22, 2026, ruling by a tribunal established under the International Chamber of Commerce (ICC) Rules of Arbitration.
The tribunal rejected Tullow’s claims and upheld a tax assessment issued by the Ghana Revenue Authority (GRA) on proceeds the company received from its business interruption insurance policy.
The dispute centred on corporate income tax owed on insurance proceeds received by Tullow between the 2016 and 2019 financial years.
The company valued the original tax assessment at US$196.5 million. However, the application of a 100 per cent penalty increased the total liability to approximately US$393.09 million.
Tullow had contested the assessment, arguing that it violated tax protections provided under its petroleum agreements with Ghana. However, the tribunal ruled that the assessment did not breach the agreements.
In a statement issued on September 30, 2026, Finance Minister Dr Cassiel Ato Forson said the tribunal had also determined that the penalty was correctly imposed, the assessment was not time-barred and the GRA had acted lawfully in pursuing enforcement.
Tullow expressed disappointment with the ruling and indicated that it would consider its options following further discussions with the government.
Dr Forson said the government intended to work with the company to implement the tribunal’s decision in line with Ghanaian law, while considering the need to maintain operations and investment in the Jubilee and Tweneboa, Enyenra and Ntomme (TEN) oilfields.
He also disclosed that discussions with Tullow would cover a separate tax dispute concerning the disallowance of deductions on loan interest.
The government has clarified that the two matters are distinct, noting that the September arbitration ruling dealt exclusively with the tax assessment on proceeds from the business interruption insurance policy.
It has maintained that its objective is to recover revenue owed to the state without disrupting Tullow’s operations and investment activities in Ghana.
Tullow operates the Jubilee and TEN oilfields, which play an important role in the country’s oil production and domestic gas supply.
About The Author
