Tullow Ghana Secures Tribunal Victory In $320 Million Tax Dispute With GRA
The International Chamber of Commerce (ICC) Tribunal has ruled in favor of Tullow Ghana regarding the application of Branch Profit Remittance Tax (BPRT) under the Deepwater Tano and West Cape Three Points Petroleum Agreements.
This decision, delivered on January 2, 2025, affirms that BPRT does not apply to Tullow Ghana’s operations, including those in the Jubilee and TEN fields offshore Ghana.
As a result of the ruling, Tullow Ghana is no longer liable for the $320 million BPRT assessment issued by the Ghana Revenue Authority (GRA). The Tribunal’s decision also ensures that the company will not face future BPRT liabilities under the Petroleum Agreements.
Tullow Ghana is actively engaging with the Government of Ghana to resolve two other disputed tax claims, which were referred to the ICC in February 2023. The company aims to achieve a mutually acceptable resolution to these issues.
Commenting on the Tribunal’s decision, Tullow Chief Executive Officer, Rahul Dhir, stated: “We are delighted with the outcome and decision of the Tribunal, which affirms our assessment and removes a material overhang from our business. We have continuously had confidence in the sanctity of our Petroleum Agreements and the dispute resolution process, which has now brought certainty to all parties. I look forward to constructive discussions with the Government of Ghana to resolve the remaining claims so that our collective focus remains on maximising value from the Jubilee and TEN fields.”
The Tribunal’s ruling underscores the importance of honouring contractual agreements in the oil and gas sector, particularly in fostering investor confidence and ensuring the stability of Ghana’s petroleum industry.
