The Federal Government has issued transition guidelines for implementing the Tax Acts 2025, clarifying how taxpayers and businesses will move from the current tax regime to the new framework that takes effect on January 1, 2026.
Transition Rules for Existing Tax Obligations
Under the guidelines, tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before January 1, 2026, will continue to be handled under the repealed tax laws
Tax returns for accounting periods ending before that date must also be filed under the old regime, while returns for accounting periods ending from January 1, 2026, onward will be processed under the new tax framework.
Issued by the Federal Ministry of Finance, the guidelines are intended to help taxpayers, tax practitioners, revenue authorities and other stakeholders navigate the transition to Nigeria’s new tax system.
The new tax framework comprises the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act and the Joint Revenue Board (Establishment) Act. While each law takes effect on its respective commencement date, the Nigeria Tax Act becomes operational on January 1, 2026.
Tax Incentives and New Applications
The guidelines state that existing tax incentives and exemptions granted under the repealed laws will remain valid until their expiration dates. However, new applications and pending requests will be considered under the provisions of the Tax Acts 2025.
The document also explains how income taxes, transaction taxes, development levies, record-keeping obligations and transactions spanning both the old and new tax regimes will be treated during the transition.
FG Seeks Smooth Implementation
Speaking on the release of the guidelines, the Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, said the document provides a clear framework for managing transitional issues while ensuring the new laws are not applied retrospectively.
He described the Tax Acts 2025 as a major milestone in Nigeria’s tax reform programme, saying the guidelines provide certainty on how existing obligations, ongoing matters and future transactions will be handled under the new regime.
According to Oyedele, the transition framework is anchored on three principles—clarity, fairness and administrative certainty—and is intended to promote uniform implementation across the Nigeria Revenue Service, State Internal Revenue Services, the FCT Internal Revenue Service, Local Government Revenue Committees, tax practitioners and taxpayers nationwide.
The Federal Government said the reforms are part of its broader effort to build a transparent, efficient and modern tax system that supports economic growth, strengthens revenue administration, encourages voluntary compliance and improves Nigeria’s investment climate.
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