GRA welcomes tribunal ruling upholding US$393m tax assessment against Tullow

The Ghana Revenue Authority (GRA) has welcomed a decision by an international arbitral tribunal upholding its US$393,091,993.70 tax assessment against Tullow Ghana Limited.

The tribunal, constituted under the International Chamber of Commerce Rules of Arbitration, dismissed claims Tullow Ghana Limited brought against the Republic of Ghana over the taxation of business interruption insurance proceeds.

Tullow ordered to pay US$393m after losing tax case against Ghana

According to a statement issued by the GRA on September 30, 2026, the tribunal “dismissed the claims brought by Tullow Ghana Limited and upheld the GRA’s tax assessment of US$393,091,993.70.”

It further ruled that the assessment did not breach the applicable Petroleum Agreements, was not time-barred, and that the GRA’s enforcement action was lawful.

The Authority said the decision “affirms the Authority’s position that the assessment was made in accordance with Ghana’s tax laws and reinforces the principle that all taxpayers, irrespective of their size or sector, are subject to the laws of the Republic.”

The GRA noted that it “recognises the important contribution of the petroleum sector to Ghana’s economy” and remains committed to administering tax laws in a manner that is “fair, transparent, consistent and predictable.”

Its objective, the Authority said, “is not only to mobilise the revenue required for national development, but also to ensure that taxpayers are treated fairly and that Ghana continues to provide a stable environment for legitimate business and investment.”

The GRA acknowledged the leadership of the Government of Ghana and the support of the Office of the Attorney-General and Ministry of Justice, the Ministry of Finance, and Ghana’s external legal counsel, Foley Hoag LLP.

It also commended its officers and technical teams “whose professional work, diligence and commitment contributed to the successful defence of the assessment.”

The GRA said it “will work closely with the Government and Tullow Ghana Limited to give effect to the award in accordance with Ghanaian law.”

Implementation, it noted, “will take due account of the need to secure revenues lawfully due to the State while supporting the continuity of operations and investment in the Jubilee and TEN fields.”

The Authority reaffirmed its commitment “to constructive engagement with all taxpayers” and encouraged businesses operating in Ghana “to continue to meet their tax obligations fully and promptly.”

It further stated that it “will continue to administer Ghana’s tax laws without fear or favour, while strengthening voluntary compliance and maintaining a fair and predictable tax environment.”

Read the statement below

NA/MA

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