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Ghana-Tullow Oil tax arbitration dispute

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What changed

2026-10-02 13:42 UTC → 2026-10-18 05:32 UTC · added removed

An International Chamber of Commerce (ICC) tribunal ruled in favor of Ghana in a tax dispute against Tullow Ghana Limited, upholding has upheld a US$393,091,993.70 tax assessment issued by the Ghana Revenue Authority (GRA). (GRA) against Tullow Ghana Limited (TGL). The dispute concerned income tax liabilities for the 2016–2019 period regarding proceeds from business interruption insurance. The tribunal In a final award issued on 22 September 2026, the London-seated tribunal, presided over by Prof. Albert Jan van den Berg, unanimously dismissed Tullow’s claims, determining 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. While Tullow Oil expressed disappointment The ruling specifically concerns TGL’s operations under agreements for West Cape Three Points and indicated it is considering next steps, 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.

Versions

  1. 2026-10-18 05:32 UTC Ghana-Tullow Oil tax arbitration dispute
  2. 2026-10-02 13:42 UTC Ghana-Tullow Oil tax arbitration dispute

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