The Federal Government has released comprehensive transition guidelines for the implementation of the Tax Acts 2025, providing clarity on how taxpayers, revenue authorities and other stakeholders will move from the existing tax regime to a new framework scheduled to take effect from January 1, 2026.
The guidelines, issued by the Federal Ministry of Finance, set out procedures for handling tax matters during the transition period and address issues arising from the repeal of existing tax laws and the introduction of the new tax framework.
According to the ministry, 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. The guidelines state that the laws will take effect from their respective commencement dates as provided in each Act, with the Nigeria Tax Act, 2025, taking effect on January 1, 2026.
The document explains that tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before the commencement date will continue to be governed by the repealed tax laws.
It further states that tax returns for accounting periods ending before January 1, 2026, will be filed under the existing laws, while returns due from January 1, 2026, onwards will be administered under the new tax framework.
The guidelines also provide direction on the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping requirements and transactions spanning both the old and new tax regimes.
Under the transition arrangements, existing tax incentives and exemptions granted under repealed laws will remain valid until their expiration dates.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.
Speaking on the release of the guidelines, the Honourable Minister of Finance and Coordinating Minister of the Economy, Mr Taiwo Oyedele, said the document was designed to ensure a smooth transition and prevent retrospective application of the new laws.
He said, “the document 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 significant milestone in Nigeria’s tax reform programme,” adding that the guidelines clearly define how existing obligations, ongoing matters and future transactions will be treated under the new regime.
According to the minister, the guidelines are built around three core principles, “clarity, fairness and administrative certainty.”
The ministry said the guidelines are intended to ensure uniform implementation and effective administration 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 reiterated its commitment to creating a transparent, efficient and modern tax system capable of supporting economic growth, strengthening revenue administration, encouraging voluntary compliance and improving Nigeria’s investment climate.
The guidelines take effect as Nigeria prepares for one of its most significant tax reforms in recent years, with authorities seeking to provide certainty and consistency for businesses and taxpayers ahead of the January 2026 commencement date.
Faridah Abdulkadiri
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