Tullow Oil Wins $320 Million Tax Dispute Against Ghana
Tullow Oil Exempted from $320 Million Tax Assessment, Tribunal Rules in Favor
- Tullow Oil PLC has secured a major legal victory in its ongoing tax dispute with Ghana
- This ruling effectively exempts Tullow Ghana from the $320 million BPRT assessment issued by the GRA
- The company has reiterated its commitment to resolving these issues amicably
Tullow Oil PLC has secured a major legal victory in its ongoing tax dispute with the Ghana Revenue Authority (GRA), after the International Chamber of Commerce (ICC) Tribunal ruled in its favor.
The Tribunal determined that the Branch Profit Remittance Tax (BPRT) does not apply to Tullow Ghana’s operations under the Deepwater Tano and West Cape Three Points Petroleum Agreements, which govern the Jubilee and TEN offshore oil fields.
This ruling effectively exempts Tullow Ghana from the $320 million BPRT assessment issued by the GRA, ensuring the company will not face any future BPRT liabilities under these agreements.
The decision reinforces the tax framework outlined in the Petroleum Agreements, which Tullow argued should govern its operations.
As a result of the Tribunal’s decision, Tullow stated that it is not liable to pay the $320 million BPRT assessment and will not have future exposure to the tax for its operations under the agreements.
“Tullow continues to engage with the Government of Ghana on two further disputed tax claims, which were referred to the ICC in February 2023, with the aim of resolving these disputes on a mutually acceptable basis,” the company noted in a press release.
Tullow’s CEO, Rahul Dhir, expressed his satisfaction with the outcome, saying, “We are delighted with the Tribunal’s decision, which validates our position and removes a significant overhang from our business. We have always had confidence in the sanctity of our Petroleum Agreements and the dispute resolution process, and this outcome brings clarity and certainty to all parties involved.”
Despite the resolution of the BPRT dispute, Tullow remains engaged in discussions with the Government of Ghana over two additional tax disputes that were referred to the ICC in February 2023.
The company has reiterated its commitment to resolving these issues amicably, allowing it to focus on maximizing the value of its critical assets in the Jubilee and TEN fields, which are key to Ghana’s oil and gas sector.
