The Federal Government has released comprehensive transition guidelines to facilitate the smooth implementation of Nigeria’s newly enacted Tax Acts 2025 and ensure an orderly shift from the repealed tax laws.
The guidelines, unveiled on Thursday in Abuja, provide taxpayers, tax practitioners, revenue authorities, businesses, and other stakeholders with a clear roadmap for navigating the new tax framework, which takes effect on January 1, 2026.
Speaking at the unveiling, the Minister of Finance and Coordinating Minister of the Economy, Mr. Taiwo Oyedele, described the Tax Acts 2025 as a significant milestone in Nigeria’s tax reform agenda. He explained that the guidelines were developed to address transitional challenges and ensure that the provisions of the new laws are not applied retrospectively.
According to Oyedele, the framework is built on three key principles: clarity, fairness, and administrative certainty. He noted that the guidelines are designed to promote uniform implementation of the reforms and support efficient tax administration across the Nigeria Revenue Service (NRS), State Internal Revenue Services, the Federal Capital Territory Internal Revenue Service, Local Government Revenue Committees, tax practitioners, and taxpayers nationwide.
The minister stated that the document provides clear direction on the treatment of existing obligations, ongoing matters, and future transactions as the country transitions to the new tax regime.
A key provision of the framework is that tax obligations arising before the commencement date of the new laws will continue to be governed by the repealed tax legislation. In contrast, liabilities and obligations arising from January 1, 2026, onward will be administered under the new tax framework.
The guidelines also clarify that tax returns relating to accounting periods ending before January 1, 2026, will be filed and assessed under the existing tax laws. Returns due from the commencement date of the reforms, however, will be governed by the provisions of the Tax Acts 2025.
The document addresses a wide range of transition issues, including the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping requirements, audits, investigations, disputes, and enforcement actions that may span both the old and new tax regimes.
According to the guidelines, 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, each taking effect in line with the commencement dates specified in the legislation. The Nigeria Tax Act 2025 is scheduled to become operational on January 1, 2026.
The government further clarified that tax liabilities, assessments, audits, investigations, disputes, and enforcement actions relating to periods before the commencement date will continue to be handled under the repealed laws.
To provide certainty for businesses and investors, the Federal Government confirmed that tax incentives and exemptions granted under the previous tax framework will remain valid until their expiration dates. However, new applications and pending requests for incentives will be considered under the provisions of the new tax laws.
The government reaffirmed its commitment to building a transparent, efficient, and modern tax system that supports economic growth, strengthens revenue administration, encourages voluntary compliance, and enhances Nigeria’s attractiveness as an investment destination.
The release of the transition guidelines marks a major step in the implementation of one of Nigeria’s most far-reaching tax reform programmes, providing businesses and taxpayers with greater certainty ahead of the January 2026 commencement date.
