The Federal Government has issued comprehensive transition guidelines for the implementation of the Tax Acts 2025. This document clarifies how taxpayers, tax authorities, and other stakeholders should manage obligations arising from the migration from the old tax regime to the new framework, which became effective on January 1, 2026.
The guidelines, issued by the Federal Ministry of Finance, provide direction on the treatment of tax liabilities, assessments, audits, investigations, disputes, and enforcement actions related to periods both before and after the commencement of the new tax laws.
The Tax Acts 2025 include the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act. These laws apply from their respective commencement dates as stipulated.
Tax liabilities, assessments, audits, investigations, disputes, and enforcement actions pertaining to periods before the commencement date will continue to be handled under the repealed tax laws. Similarly, tax returns for accounting periods ending before January 1, 2026, will be filed under the old laws, while returns due from January 1, 2026, onward will be administered under the new framework.
The guidelines also address the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping obligations, and transactions that span both tax regimes. Importantly, tax incentives and exemptions granted under repealed laws will remain valid until their expiration dates.
However, new applications and pending requests for incentives will be considered under the provisions of the Tax Acts 2025. Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, stated that the document aims to provide clarity on transitional issues without applying the new laws retrospectively.
Oyedele described the Tax Acts 2025 as a significant milestone in Nigeria’s tax reform programme. The framework is anchored on the principles of clarity, fairness, and administrative certainty, outlining how existing obligations, ongoing matters, and future transactions will be treated under the new regime.
The Ministry intends for the guidelines to promote uniform implementation across the Nigeria Revenue Service, state internal revenue services, the Federal Capital Territory Internal Revenue Service, local government revenue committees, tax practitioners, and taxpayers nationwide. The government remains committed to fostering a transparent, efficient, and modern tax system to support economic growth, enhance revenue administration, encourage voluntary compliance, and improve the country’s investment climate.
