Ghana Tax3 Nov 2024 08:19
Only one part of the tax disputes expected to be settled in 2024. Other two of unknown timeframe.
Ghana tax assessments
A further arbitration hearing was conducted in June 2024 in respect of the assessment for Branch Profits Remittance Tax (BPRT). This claim relates to the Ghana Revenue Authority (GRA) seeking to apply BPRT under a law which the Group considers is not applicable to Tullow Ghana Limited, since it falls outside the tax regime provided for in the Petroleum Agreements and relevant double tax treaties. Tullow referred this case to international arbitration in October 2021 and a decision from the panel is expected in the second half of the year. Tullow has two further ongoing disputed tax assessments that relate to the disallowance of loan interest deductions for the fiscal years 2010 - 2020 and proceeds received by Tullow Oil plc under Tullow's corporate Business Interruption Insurance policy. Both were referred to international arbitration in 2023, with first hearings scheduled for 2025, however Tullow continues to engage with the Government of Ghana, including the GRA, with the aim of resolving the assessments on a mutually acceptable basis.