The Federal Government has released comprehensive transition guidelines for the implementation of the Tax Acts 2025, providing clarity for taxpayers, tax authorities and other stakeholders as Nigeria moves from the old tax regime to a new framework that took effect on January 1, 2026.
The guidelines were announced in a statement issued on Thursday by the Head of Information and Public Relations Unit at the Federal Ministry of Finance, Efe Ovuakporie.
According to the ministry, the document outlines how tax liabilities, assessments, audits, investigations, disputes and enforcement actions will be handled during the transition from the repealed tax laws to the new tax framework.
“The Federal Government has issued the General Guidelines for the Implementation of the Tax Acts 2025, setting out the process for transition from the repealed tax laws to the new tax framework effective from January 1, 2026,” the statement said.
The ministry explained that the Tax Acts 2025 comprise the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act and the Joint Revenue Board (Establishment) Act.
It noted that these laws will apply from their respective commencement dates as specified in the legislation.
Under the guidelines, tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before January 1, 2026, will continue to be governed by the repealed tax laws.
Similarly, tax returns covering accounting periods ending before the commencement date will be filed under the previous tax framework. However, returns due from January 1, 2026, onward will be administered under the new tax regime.
The ministry stated that 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.
According to the document, tax incentives and exemptions granted under the repealed laws will remain valid until their expiration dates. New applications and pending requests for incentives, however, will be considered under the provisions of the Tax Acts 2025.
Speaking on the significance of the guidelines, the Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, said the framework was designed to ensure a smooth transition while preventing the retrospective application of the new laws.
“The document provides a framework for managing transitional issues while ensuring that the new laws are not applied retrospectively,” Oyedele said.
He described the Tax Acts 2025 as a landmark achievement in Nigeria’s tax reform agenda, noting that the guidelines clearly define how existing obligations, ongoing matters and future transactions will be treated under the new system.
According to the minister, the transition framework is built on three key principles: clarity, fairness and administrative certainty.
The ministry added that the guidelines are intended to ensure 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.
It further stated that the government remains committed to developing a transparent, efficient and modern tax system capable of supporting economic growth, strengthening revenue administration, promoting voluntary compliance and improving Nigeria’s investment climate.
The release of the guidelines marks another major step in the implementation of the Tax Acts 2025, which introduced significant reforms to the country’s tax administration framework and are expected to reshape tax collection and compliance processes across Nigeria.
