For the first time since Ghana began commercial oil production in 2010, corporate tax from petroleum companies has overtaken the state’s direct share of crude as the single largest source of oil revenue and the reason reveals a long-standing structural question about how Ghana designed its oil fiscal terms.
The Public Interest and Accountability Committee (PIAC), presenting its 2025 Annual Report in Accra on Wednesday, April 8, confirmed that Corporate Income Tax (CIT) contributed US$346.8 million, or 45 percent of total petroleum receipts, topping all other revenue streams for the first time. Chairman Richard Ellimah explained the shift directly: companies have been exhausting their capital allowances and are now beginning to pay more taxes.
Capital allowances, written into every petroleum agreement Ghana signed with international oil companies (IOCs), allow operators to deduct exploration, development, and production costs from their taxable profits before corporate tax is calculated. For major producers such as Tullow Ghana, Kosmos Energy, and ENI Ghana — which invested billions of dollars into developing the Jubilee, Tweneboa-Enyenra-Ntomme (TEN), and Sankofa Gye Nyame (SGN) fields, this meant legally reduced corporate tax bills for the better part of a decade and a half while those costs were being recovered.
The arrangement is standard in global oil contracts and was designed deliberately to attract investment into Ghana’s then-unproven offshore sector. It was not evasion or non-compliance. But it meant that Ghana’s full corporate tax harvest was always going to arrive late in the production cycle and it has now arrived precisely as output declines. Total petroleum receipts fell to US$770.3 million in 2025 from US$1.36 billion in 2024, a drop of 43.27 percent.
ENI Ghana, Vitol Upstream, and Tullow Ghana were among the major CIT contributors in 2025, with Kosmos Energy and PetroSA also among the companies paying into the Petroleum Holding Fund (PHF). CIT payments from petroleum companies rose in the second half of 2025, reaching US$198.09 million compared to approximately US$144 million in the same period of 2024.
A separate but related issue flagged by PIAC concerns surface rental arrears, smaller annual fees owed by companies for their contract areas. Arrears remained elevated, with about 60 percent owed by three companies whose petroleum agreements had already been terminated in 2021. These are relatively small amounts but represent a compliance gap that the Ghana Revenue Authority (GRA) and the Petroleum Commission have been slow to close.
The broader picture PIAC is drawing is one of a fiscal structure reaching the end of its designed lifecycle at the worst possible moment. Ghana has no new oil discoveries, no new petroleum agreements since 2018, and no new fields entering production. As the major operators exhaust their remaining cost recovery positions, CIT payments are likely to decline again rather than continue rising because there will be less profit to tax as production falls.
PIAC has called on the government to review the regulatory and fiscal framework to ensure any new petroleum agreements attract adequate revenue for Ghana at every stage of field development, not only at its end.
