Finance Minister Dr Cassiel Ato Forson says the government will ensure Ghana receives the revenues due from Tullow Ghana Limited following the country’s victory in an international tax arbitration, while safeguarding the company’s ability to sustain its operations and investments.
An arbitral tribunal constituted under the International Chamber of Commerce (ICC) Rules of Arbitration delivered its award on Tuesday, September 29, 2026, dismissing all claims brought by Tullow and upholding in full the Ghana Revenue Authority’s (GRA) tax assessment of US$393,091,993.70. The tribunal also found that the assessment did not breach the Petroleum Agreements, the penalty was properly applied, the assessment was not time-barred, and the GRA’s enforcement action was lawful.
A Vital Partner, Not Just a Taxpayer
Dr Forson said the government recognises Tullow’s importance to Ghana’s petroleum sector, describing the company as “a vital partner to Ghana” and the country’s largest petroleum producer. In a press statement issued on Wednesday, September 30, he noted that Tullow’s operations in the Jubilee and TEN fields contribute to energy security, domestic gas supply and thousands of Ghanaian livelihoods.
“The Government will therefore work closely with Tullow to give effect to the award in accordance with Ghanaian law,” he said. “In doing so, the Government will have due regard to the continuity of operations in the Jubilee and TEN fields and Tullow’s capacity to sustain the investments required in those fields”.
The Finance Minister also disclosed that government had been engaged in discussions with Tullow before the tribunal’s decision to resolve outstanding tax matters amicably. Those discussions will continue, covering both the matter determined by the tribunal and separate proceedings concerning the disallowance of loan interest.
“The Government intends to ensure that the award is implemented in a way that secures the revenues due to the Ghanaian people while preserving Tullow’s ability to continue operating and investing in Ghana as a going concern,” he added.
A Long-Running Dispute Over Insurance Proceeds
The dispute began in December 2022, when the GRA issued Tullow a corporate income tax assessment of US393 million figure upheld by the tribunal includes a 100% penalty on the underlying assessment.
The case is part of a broader pattern of tax disputes between Tullow and Ghanaian authorities. In October 2021, Tullow filed a separate ICC arbitration disputing a US$320.3 million Branch Profits Remittance Tax assessment for the financial years 2014 to 2016. A tribunal ruled in January 2025 that the BPRT was not applicable to Tullow Ghana, meaning the company was not liable to pay that assessment.
A separate US$190.5 million assessment relating to the disallowance of loan interest for the financial years 2010 to 2020 remains unresolved. That dispute will go to a tribunal hearing in 2027.
Tullow’s Significant Presence in Ghana
Tullow has consolidated its business around its high-value Ghana assets following disposals in Gabon, Equatorial Guinea, Kenya and Côte d’Ivoire, with the Jubilee and TEN fields remaining its principal producing assets. The company signed a Memorandum of Understanding with the Government of Ghana to extend production licences for both Jubilee and TEN to 2040.
The financial stakes are considerable. Tullow reported first-half 2026 revenue of US411 million a year earlier, with gross profit rising to US165 million. Production from Jubilee and TEN averaged 43,700 barrels of oil equivalent per day in the first half, up more than 7% year-on-year. The company raised its 2026 free cash flow guidance to between US250 million, from a prior range of US175 million.
However, Tullow recorded a loss after tax of US80 million in the same period of 2025, and its net debt stood at US$1.4 billion as of June 2026.
Market Reaction: Shares Crash 50%
The arbitration ruling triggered a sharp selloff in Tullow’s London-listed shares. The stock opened Wednesday’s trading session at around 15.94 pence and dropped as low as about 9.73 pence, a decline of as much as 52%—its steepest intraday fall since 2020. The crash reversed a rally that had pushed the stock up nearly 88% between March and September 2026.
Panmure Liberum analyst Ashley Kelty described the reaction as overdone but warned about the company’s broader financial position. “The loss of the tax case is not a huge surprise, but the problem is that until they make some decent progress on paying down debt, I can’t see long-term survival really for the company,” he said.
Tullow said it was “disappointed” with the ruling and would consider its next steps after further engagement with the Government of Ghana. “Tullow is disappointed that the Tribunal has come to this decision and will now consider next steps after further engagement with the Government of Ghana,” the company said in a statement to investors.
GRA to Collaborate on Settlement
The Ghana Revenue Authority has separately assured that it will work with Tullow Ghana to settle the US$393 million tax liability without disrupting the company’s petroleum operations. Ghana’s laws provide the GRA with the means to determine the time and manner in which assessed liabilities are met.
What Happens Next
The government’s position suggests that the immediate focus following the arbitration award will be on balancing recovery of the assessed tax liability with the continued operation and investment of Tullow in Ghana’s upstream petroleum sector.
The separate dispute over the disallowance of loan interest remains unresolved, with government and Tullow expected to continue discussions on that matter ahead of the 2027 tribunal hearing. How the government implements the award—and whether Tullow can absorb the financial impact while sustaining its Jubilee and TEN operations—will determine the future of one of Ghana’s most significant petroleum partnerships.
