The Meridian

Tullow Oil v Government of Ghana: ICC tax arbitration on business interruption insurance proceeds

30 September 2026 Public record

Value
US$196.5m
Date
30 September 2026
Status
Award issued
Transaction type
Arbitration
Practice area
Dispute Resolution and Arbitration, Energy and Natural Resources, Tax
Sector
Oil and Gas
Jurisdiction
Ghana, United Kingdom
Client
Government of Ghana (Respondent (successful))

Summary

An ICC tribunal found that Ghana’s US$196.5 million corporate income tax assessment on Tullow Oil’s business interruption insurance proceeds for 2016 to 2019 did not breach the company’s Petroleum Agreements, and that 100% penalties fall outside the agreements’ contractual protections. Tullow announced the award on 30 September 2026.

Why it matters

Tullow's contractual protection argument under its Petroleum Agreements failed against a tax assessment on insurance proceeds, with direct consequences for its Ghana-dependent cash flows and for how upstream investors read fiscal protections in West African petroleum contracts.

Scope of legal work

Counsel to the parties and the composition of the tribunal were not disclosed in the announcements reviewed by The Meridian. The GRA has put the total obligation, including penalties and interest, at about US$393 million.

Other parties

Tullow Oil plc (claimant)
Government of Ghana (respondent)
Ghana Revenue Authority (assessing authority)

Sources

Compiled by Meridian from the public announcements and filings listed under Sources.

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