Tullow Oil PLC has announced a significant legal victory in its tax dispute with the Ghana Revenue Authority (GRA).

The International Chamber of Commerce (ICC) Tribunal has ruled 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 cover the Jubilee and TEN offshore oil fields.

The decision by the Tribunal exempts Tullow Ghana from the $320 million BPRT assessment issued by the GRA and ensures the company will not face future BPRT liabilities for its operations under these agreements.

This ruling solidifies the tax framework outlined in the Petroleum Agreements which Tullow argued was the governing regime for its operations.

“As a result of the Tribunal’s award, Tullow Ghana is not liable to pay the $320 million BPRT assessment issued by the Ghana Revenue Authority and will have no future exposure to BPRT in respect of its operations under the Petroleum 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 said in a press release.

Tullow CEO Rahul Dhir expressed satisfaction with the decision, stating, “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.”

Despite this resolution, Tullow remains engaged in discussions with the Government of Ghana over two additional tax disputes, which were referred to the ICC in early 2023.

The company has expressed its commitment to resolving these issues amicably and shifting focus to maximizing value from the Jubilee and TEN fields – critical assets in Ghana’s oil and gas sector.