The government and Tullow Ghana Limited have agreed on a roadmap to address a US$393.09 million tax liability upheld by an international arbitration tribunal.
President John Dramani Mahama announced this at the 2026 Local Content Conference and Exhibition in Takoradi, where he said the two parties had reached a mutually acceptable arrangement following the arbitration ruling.
The agreement follows a September 22, 2026, ruling by a tribunal constituted under the Rules of Arbitration of the International Chamber of Commerce (ICC).
The tribunal dismissed Tullow's claims and upheld a tax assessment by the Ghana Revenue Authority (GRA) on proceeds from the company's business interruption insurance policy.
The dispute concerned corporate income tax payable on insurance proceeds received by Tullow during the 2016 to 2019 financial years.
The company put the underlying tax assessment at US$196.5 million. A 100 per cent penalty brought the total liability to approximately US$393.09 million.
Tullow had challenged the assessment, arguing that it breached the tax protections contained in its petroleum agreements with Ghana. The tribunal ruled that the assessment did not violate those agreements.
In a statement issued on September 30, 2026, the Finance Minister, Dr Cassiel Ato Forson, said the tribunal also found that the penalty had been properly applied, the assessment was not time-barred, and the GRA's enforcement action was lawful.
Tullow expressed disappointment with the ruling and said it would consider its next steps after further engagement with the government.
Dr Forson said the government would work with the company to implement the ruling in accordance with Ghanaian law, while taking into account the need to sustain operations and investment in the Jubilee and Tweneboa, Enyenra and Ntomme (TEN) oilfields.
He also indicated that discussions with the company would extend to a separate tax dispute involving the disallowance of loan-interest deductions.
The two disputes are separate. The September arbitration ruling dealt specifically with the tax assessment on proceeds from the business interruption insurance policy.
The government has said it wants to recover revenue due to the state while allowing Tullow to continue operating and investing in Ghana.
Tullow operates the Jubilee and TEN oilfields, which contribute to the country's oil production and domestic gas supply.
