The Federal Government has issued transition guidelines for the implementation of the Tax Acts 2025, outlining how taxpayers and authorities will move from the old tax system to the new framework effective 1 January 2026.
The guidelines, released by the Federal Ministry of Finance, aim to clarify how obligations, disputes, and ongoing transactions will be handled during the transition period.
According to the document, the Tax Acts 2025 — comprising the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act — will take effect based on their respective commencement dates.
It noted that 1 January 2026 is the commencement date for the Nigeria Tax Act, 2025.
The government clarified that tax liabilities, assessments, audits, investigations and enforcement actions relating to periods before that date will continue to be handled under the repealed tax laws.
Similarly, tax returns for accounting periods ending before 1 January 2026 will be filed under the old regime, while those from that date onward will be governed by the new framework.
The guidelines also address the treatment of income taxes, transaction taxes, development levies, tax incentives and exemptions, as well as record-keeping obligations and transactions spanning both regimes.
Existing tax incentives and exemptions granted under the repealed laws will remain valid until their expiration, while new applications and pending requests will be considered under the new tax laws.
Speaking on the release of the guidelines, the Minister of Finance and Coordinating Minister of the Economy, Mr Taiwo Oyedele, said the document provides a structured approach to managing the transition.
He said it “provides a framework for managing transitional issues while ensuring that the new laws are not applied retrospectively.”
Oyedele described the Tax Acts 2025 as a major milestone in Nigeria’s tax reform program, noting that the guidelines clearly outline how existing obligations, ongoing matters, and future transactions will be treated.
According to him, the framework is anchored on three key principles — clarity, fairness, and administrative certainty.
He 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.
The Federal Government reaffirmed its commitment to building a transparent, efficient, and modern tax system to strengthen revenue administration, encourage voluntary compliance, and improve Nigeria’s investment climate.
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