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From Adanna Nnamani, Abuja
The Federal Government has issued comprehensive guidelines to facilitate the transition from Nigeria’s repealed tax laws to the new tax framework established under the Tax Acts 2025, providing clarity for taxpayers, tax practitioners, revenue authorities and other stakeholders ahead of the full implementation of the reforms.
The guidelines, released by the Federal Ministry of Finance on Thursday, outline the procedures for managing tax obligations and administrative matters as the country migrates to the new tax system, which takes effect from January 1, 2026.
According to the government, the General Guidelines for the Implementation of the Tax Acts 2025 are designed to ensure a smooth transition while providing certainty on the treatment of liabilities, assessments, audits, disputes and other tax-related matters arising under the previous legal regime.
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 each law will apply from its respective commencement date as provided in the legislation, with the Nigeria Tax Act taking effect from January 1, 2026.
Under the transition arrangements, tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before the commencement date will continue to be administered under the repealed tax laws.
Similarly, tax returns for accounting periods ending before January 1, 2026, will be filed under the existing tax laws, while returns due from that date onward will be governed by the provisions of the new tax framework.
The guidelines also address the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping obligations and transactions that span both the old and new tax regimes.
In a move aimed at protecting existing investments and business arrangements, the government stated that tax incentives and exemptions granted under the repealed laws will remain valid until their expiration dates.
However, pending applications and new requests for incentives will be considered under the provisions of the Tax Acts 2025.
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 clear framework for addressing transitional issues without applying the new laws retrospectively.
He described the Tax Acts 2025 as a landmark achievement in the nation’s ongoing tax reform programme and noted that the guidelines clarify how existing obligations, ongoing matters and future transactions will be treated under the new legal framework.
According to the minister, the transition guidelines are anchored on three core principles: clarity, fairness and administrative certainty.
He added that the document is intended to promote uniform implementation of the new tax laws 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 reiterated its commitment to building a transparent, efficient and modern tax administration system capable of supporting economic growth, strengthening revenue collection, encouraging voluntary tax compliance and improving Nigeria’s investment climate.
