ExxonMobil startled observers when it told United States (U.S.) regulators it paid over US$1.2 billion in taxes to Guyana in 2024. But that figure, the company acknowledges, may not reflect its real tax burden—and critics argue it is more of a paper exercise enabled by contractual loopholes.
In its Securities and Exchange Commission (SEC) disclosure, ExxonMobil reported payments to the Guyana Revenue Authority (GRA), along with royalties, fees, and an US$8.9 million infrastructure grant to Guyana’s Ministry of Culture, Youth and Sport. But the company also conceded that “the tax payments reported … do not equal our ultimate tax liability” and do not account for tax credits or refunds.
That caveat matters deeply—because under the 2016 Stabroek Block Petroleum Agreement, ExxonMobil and its affiliates are legally shielded from many domestic taxes. Article 15.1 grants them exemption from corporate tax, value-added tax, excise duties, and related charges unless explicitly spelled out. Article 15.4 shifts the burden: it mandates that the Government of Guyana pay “the sum equivalent to the taxes owed” to the GRA on Exxon’s behalf, issuing a receipt so the company can present itself as compliant abroad.
In effect, the Guyanese state pays the taxes—and Exxonbooks them as if it did.
Audit Disputes Reveal Millions in Questionable Claims
The tension between Exxon’s claims and the financial realities of the Stabroek agreement is further exposed through cost audits and government probes.
In 2025, Guyana’s Natural Resources ministry ordered the country’s tax authority to enter dispute resolution with Exxon over US$214 million in expenses flagged in an external audit. The IHS Markit audit, covering the period 1999–2017, recommended adjustments to the so-called “cost bank” — the pool of costs Exxon may deduct under the contract.
A second audit, covering 2018–2020 and conducted by VHE Consulting, reportedly questioned over US$70 million in costs submitted by Exxon—but its final conclusions remain under wraps.
Local transparency watchdogs and observers have repeatedly flagged that Exxon’s cost claims are being absorbed with minimal challenge. The Extractive Industries Transparency Initiative (EITI) reprimanded Guyana for failing to conclude cost audits or publish their summaries. It noted that although two audits had been conducted, no agreement has been reached on adjustments and transparency remains lacking.
These unresolved audits suggest that tens of millions in questionable cost claims may be allowing Exxon to shift revenue and reduce its apparent profit share—all while the host state (Guyana) pays the tax sticker.
Watchdog Groups Call Out Lack of Transparency and Possible Subsidies
Transparency advocates and tax campaigners argue that Exxon’s disclosures are intentionally opaque—and that the company is avoiding scrutiny.
The U.S.-based FACT Coalition, via its director, has publicly named Exxon among oil majors lagging in Global Reporting Initiative (GRI) tax disclosures. Exxon has declined to publish country-by-country tax data in the detail demanded by GRI, unlike peers.
Oxfam and other civil society actors have filed shareholder resolutions pushing Exxon to align its tax reporting with international transparency norms, arguing that opaque disclosures raise risks of profit-shifting and erode confidence in whether the company truly pays its local taxes.
Energy-sector critics are calling for formal investigations. One commentary in OGGN (Oil, Gas, and Government Network) accused Exxon of obtaining GRA tax certificates “without actually paying,” underscoring the gulf between paperwork and reality.
Why This Scheme Matters—and What It Implies
ExxonMobil, in joint venture with China’s CNOOC and Chevron (which acquired Hess), continues to exploit the 26,800-square-kilometer Stabroek Block—one of the most profitable oil discoveries in the world.
Exxon’s maneuvering is more than accounting sleight-of-hand: it reflects a deeper structural imbalance in the Guyana deal and raises serious questions about who really bears the tax burden.
Under the 2016 agreement, Exxon can recover up to 75% of gross output as “cost oil” (to recoup expenses), leaving only the remainder to be split with the government.
Critics argue that this gives the company outsized control over what gets counted as recoverable cost—and over what payments the government has “paid” in its name.
The contrast between Exxon’s grand total (US$1.2B in Guyana in 2024) and the amounts Guyana is contesting in audits (hundreds of millions) points to the possibility of overstated tax payments used for reputational and regulatory advantage.
Meanwhile, U.S. Senators Sheldon Whitehouse, Chris Van Hollen and Jeff Merkle are probing whether American taxpayers are inadvertently subsidising Exxon’s foreign oil operations. In a recent letter, they warned that under U.S. tax law, certain payments to foreign governments “in exchange for an economic benefit” are not genuine taxes—and must be carefully distinguished.
