Tullow Oil is now worth less than the US$393m tax award Ghana has won against it, after the company’s shares fell by as much as 52% in London.
The figure announced by Finance Minister Dr Cassiel Ato Forson on Tuesday consists of two equal parts: US$196.5m in corporate income tax and a 100% penalty of the same amount.
The Ghana Revenue Authority (GRA) assessed Tullow Ghana Limited for tax on money received through its business interruption insurance policy during the 2016 to 2019 financial years. The resulting total was US$393,091,993.70, although Tullow’s statement to investors referred to the US$196.5m assessment rather than the full amount.
An International Chamber of Commerce tribunal ruled that the assessment did not breach Tullow’s petroleum agreements with Ghana, was not time-barred and had been lawfully enforced.
It also found that the 100% penalties “fall outside the scope of the contractual protections” contained in those agreements. The decision means the stability and tax provisions relied on by oil companies do not cover penalties.
Tullow said it was disappointed by the ruling and would consider its next steps after further discussions with the Ghanaian government.
Its shares were trading at 10.7 pence by mid-morning on Tuesday, following their sharpest one-day decline since 2019. The fall valued the company at about £150m, or roughly US$200m at current exchange rates – approximately half the amount Ghana is entitled to collect.
Tullow’s financial position has contributed to the market reaction. The company has about US$1.4bn in debt, is selling assets in Gabon and Kenya to reduce that burden, and reported a US$101m loss after tax for the first half of 2026.
Ashley Kelty, an analyst at Panmure Liberum, told Reuters the ruling was not unexpected but added: “Until they make some decent progress on paying down debt, I can’t see long-term survival really for the company.”
Ghana seeks to protect oil production
Dr Cassiel Ato Forson said Ghanaian law allows the GRA to determine “the time and manner” in which assessed tax liabilities are paid. He said the government would give “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 stated aim is to recover the money while preserving Tullow’s ability to operate and invest in Ghana as a going concern. Discussions that began before the ruling will continue and will address both the concluded case and another dispute that remains unresolved.
Tullow is Ghana’s largest petroleum producer and operates the Jubilee and TEN fields, which support domestic gas supplies and a significant share of upstream employment.
The government is separately seeking extensions to the Jubilee and TEN petroleum agreements to attract investment into a declining basin. In February, Tullow spent US$205m buying the FPSO Prof. John Evans Atta Mills, which produces oil from the Jubilee field.
The ruling also reverses the outcome of an earlier dispute. Tullow brought the assessments to arbitration in London in February 2023, and an ICC tribunal ruled in January 2025 that Branch Profit Remittance Tax did not apply to its operations in the Deepwater Tano and West Cape Three Points fields. That decision cost Ghana US$320m in tax it had assessed and expected to receive.
Ghana’s external counsel in the latest case was Foley Hoag LLP, working with the Office of the Attorney-General and the GRA.
A third dispute remains pending over the GRA’s disallowance of loan interest deducted by Tullow against taxable profit between the 2010 and 2020 fiscal years. The revised assessment is US$190.5m and the matter is scheduled for a tribunal hearing in 2027.
