The Federal Government has released detailed transition guidelines for the implementation of the Tax Acts 2025, outlining how Nigeria will move from repealed tax laws into a unified new tax framework taking effect from January 1, 2026.
The guidelines, issued in Abuja on Thursday, provide operational clarity for taxpayers, tax practitioners, revenue authorities and other stakeholders. They are designed to ensure a smooth shift from the old tax regime to the new legal structure without disruption to ongoing obligations. They also establish how tax matters spanning both regimes will be handled during the transition period.
A major provision states that tax returns relating to accounting periods ending before January 1, 2026, will continue to be assessed under the repealed tax laws. However, any returns due from January 1, 2026, onward will fall under the new Tax Acts 2025 framework.
The document clarifies that the Tax Acts 2025 includes the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act. These will apply from their respective commencement dates, with January 1, 2026, serving as the key operational start date for the Nigeria Tax Act.
It further states that all tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before the commencement date will continue to be governed by the repealed laws.
According to the guidelines, existing tax incentives and exemptions granted under the old system will remain valid until their expiration.
New applications and pending requests will, however, be processed under the provisions of the Tax Acts 2025. The framework also addresses income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping obligations and hybrid transactions that span both old and new regimes.
Minister of Finance and Coordinating Minister of the Economy, Mr. Taiwo Oyedele, said the guidelines provide structure for managing transitional challenges while ensuring the new laws are not applied retrospectively.
He described the Tax Acts 2025 as a key milestone in Nigeria’s broader tax reform agenda, aimed at modernising revenue administration and improving compliance. According to him, the guidelines are anchored on clarity, fairness and administrative certainty.
He added that the framework is intended to promote uniform implementation across federal, state and local revenue authorities, including the Nigeria Revenue Service, state internal revenue services, the FCT IRS, local government revenue committees, taxpayers and tax professionals.
The Federal Government said the transition framework is part of broader efforts to build a more transparent and efficient tax system. Authorities say the reforms are expected to improve compliance, strengthen revenue generation and enhance Nigeria’s investment climate as the new tax regime takes effect in 2026.
