# Ghana-Tullow Oil tax arbitration dispute

> Live situation record from CLSTR: https://clstr.news/situations/ghana-tullow-oil-tax-arbitration-dispute
> Updated: 2026-10-17T22:26:32.000Z. Sources: 20. Developments: 3.

An International Chamber of Commerce (ICC) tribunal has upheld a US$393,091,993.70 tax assessment issued by the Ghana Revenue Authority (GRA) against Tullow Ghana Limited (TGL). The dispute concerned income tax liabilities for the 2016–2019 period regarding proceeds from business interruption insurance.

In a final award issued on 22 September 2026, the London-seated tribunal, presided over by Prof. Albert Jan van den Berg, unanimously dismissed TGL’s claims. While the tribunal acknowledged its jurisdiction to hear contractual disputes regarding taxation, it declined to reassess the GRA’s decision de novo. Instead, the tribunal applied a deferential approach to the authority’s discretion, ruling that the assessment did not breach existing Petroleum Agreements and that the GRA’s enforcement actions were lawful.

Ghana’s legal defense was led by Attorney-General Dominic Akuritinga Ayine, Deputy Attorney-General Justice Srem-Sai, and the law firm Foley Hoag LLP. The ruling specifically concerns TGL’s operations under agreements for West Cape Three Points and Deepwater Tano, covering the Jubilee field, but does not establish a general rule regarding the taxation of business-interruption insurance proceeds in Ghana. The GRA stated the ruling reinforces the principle that all taxpayers must comply with national laws.

## Timeline

### 2026-10-17: Ghana arbitral tribunal rejects Tullow Ghana tax challenge

An ICC arbitral tribunal rejected Tullow Ghana Limited’s challenge against a USD 393.1 million tax assessment by the Republic of Ghana, citing deference to the Ghana Revenue Authority.

2 sources. https://clstr.news/cluster/ghana-arbitral-tribunal-rejects-tullow-ghana-tax-challenge

### 2026-10-02: Ghana wins US$393m tax arbitration against Tullow Ghana

An ICC tribunal upheld a US$393 million tax assessment by the Ghana Revenue Authority against Tullow Ghana Limited, dismissing the company's claims regarding 2016–2019 income tax liabilities.

4 sources. https://clstr.news/cluster/ghana-wins-us393m-tax-arbitration-against-tullow-ghana

### 2026-09-30: Ghana wins $393m tax arbitration against Tullow Oil

An ICC tribunal ruled in favor of Ghana, upholding a $393 million tax assessment against Tullow Oil regarding insurance proceeds. Tullow expressed disappointment and is reviewing its next steps.

17 sources. https://clstr.news/cluster/ghana-wins-icc-arbitration-against-tullow-oil-in-us393m-tax-dispute

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Cite as: Ghana-Tullow Oil tax arbitration dispute. CLSTR, https://clstr.news/situations/ghana-tullow-oil-tax-arbitration-dispute