The Federal Government has issued transition guidelines for the implementation of the Tax Acts 2025, clarifying how taxpayers, tax authorities and other stakeholders should manage obligations arising from the migration from the old tax regime to the new framework that took effect on January 1, 2026.
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This was according to a statement issued on Thursday by the Head of Information and Public Relations Unit at the Federal Ministry of Finance, Efe Ovuakporie.
According to the ministry, the document provides direction on the treatment of tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before and after the commencement of the new tax laws.
“The Federal Government has issued the General Guidelines for the implementation of the Tax Acts 2025, setting out the process for transition from the repealed tax laws to the new tax framework effective from January 1, 2026,” the statement read.
The ministry explained that 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, would apply from their respective commencement dates as stipulated in the laws.
It noted that tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before the commencement date would continue to be treated under the repealed tax laws.
The guidelines further stated that tax returns relating to accounting periods ending before January 1, 2026, would be filed under the old tax laws, while returns due from January 1, 2026, onward would be administered under the new framework.
The ministry added that the document also covers the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping obligations and transactions spanning both tax regimes.
It stated that tax incentives and exemptions granted under repealed laws would remain valid until their expiration dates.
However, it added that new applications and pending requests for incentives would be considered under the provisions of the Tax Acts 2025.
Speaking on the guidelines, the Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, said the document was designed to provide clarity on transitional issues while ensuring that the new tax laws were not applied retrospectively.
Oyedele said, “that the document provides a framework for managing transitional issues while ensuring that the new laws are not applied retrospectively.”
He described the Tax Acts 2025 as a significant milestone in Nigeria’s tax reform programme, noting that the guidelines outlined how existing obligations, ongoing matters and future transactions would be treated under the new regime.
According to the minister, the framework is anchored on three principles of clarity, fairness and administrative certainty.
The ministry said the guidelines were intended to promote 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.
It added that the government remained committed to building a transparent, efficient and modern tax system capable of supporting economic growth, strengthening revenue administration, encouraging voluntary compliance and improving the country’s investment climate.
The release of the guidelines comes as authorities continue the implementation of the Tax Acts 2025, which introduced major changes to Nigeria’s tax administration framework and are expected to reshape tax collection and compliance processes across the country.
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