The transition guidelines on the Tax Acts 2025 to provide direction to taxpayers, tax practitioners, revenue authorities and other stakeholders on how to address various issues arising from the old regime to the new framework have been released by the federal government.
The framework was issued on Thursday via a statement signed by the Director of Press Relations in the Federal Ministry of Finance, Efe Ovuakporie.
The guidelines set out the process for transition from the repealed tax laws to the new tax framework effective January 1, 2026.
Under the guidelines, 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, apply from the respective commencement dates as enacted in each law. In particular, January 1, 2026, for the Nigeria Tax Act, 2025.
Tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before that date will be treated under the repealed tax laws, the notice stated.
Tax returns relating to accounting periods ending before January 1, 2026, will be filed under the previous tax laws, while returns relating to accounting periods ending from January 1, 2026, onward will be administered under the new tax framework.
The document also covers 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.
Existing tax incentives and exemptions granted under the repealed laws will remain in place until their expiration dates. New applications and pending requests, however, will be considered under the provisions of the Tax Acts 2025.
The Minister of Finance and Coordinating Minister of the Economy, Mr Taiwo Oyedele, described the Tax Acts 2025 as a significant milestone in Nigeria’s tax reform programme, noting that the Guidelines set out how existing obligations, ongoing matters and future transactions will be treated under the new regime.
According to the Minister, the guidelines are anchored on three key principles – clarity, fairness and administrative certainty, adding that they are intended to promote uniform implementation and support 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.