The Federal Government has released comprehensive transition guidelines for the implementation of the Tax Acts 2025, setting out how Nigeria will migrate from repealed tax laws to the new tax framework scheduled to take effect on January 1, 2026.
Issued by the Federal Ministry of Finance, the guidelines are designed to provide clarity for taxpayers, tax practitioners, revenue authorities and other stakeholders on the administration of tax obligations during the transition period.
Four New Tax Laws to Drive Reform
The Tax Acts 2025 comprise four major legislations:
Nigeria Revenue Service (Establishment) Act
Nigeria Tax Act
Nigeria Tax Administration Act
Joint Revenue Board (Establishment) Act
While the Nigeria Tax Act, 2025 will take effect on January 1, 2026, the other Acts will become operational from their respective commencement dates as enacted.
Clear Divide Between Old and New Tax Regimes
According to the guidelines, all 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disputes and enforcement actions relating to periods before January 1, 2026, will continue to be governed by the repealed tax laws.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 for accounting periods ending before that date will be filed under the previous legal framework.
However, all tax returns due from January 1, 2026, onward will be administered under the new tax regime.
The guidelines also provide direction on the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping requirements and transactions that span both the old and new systems.
Existing Tax Incentives Remain Protected
The Federal Government assured businesses and investors that existing tax incentives and exemptions granted under repealed laws will remain valid until their expiration dates.
However, new applications and pending requests for incentives will be assessed under the provisions of the Tax Acts 2025.
Focus on Clarity, Fairness and Certainty
Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, said the guidelines were developed to prevent the retrospective application of the new laws while ensuring a seamless transition.
Describing the Tax Acts 2025 as a landmark achievement in Nigeria’s tax reform agenda, he noted that the framework is anchored on three key principles — clarity, fairness and administrative certainty.
According to him, the guidelines are intended to ensure 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 government reaffirmed its commitment to building a transparent, efficient and modern tax system that promotes economic growth, strengthens revenue administration, encourages voluntary compliance and enhances Nigeria’s investment climate.
