Federal Government has issued general guidelines for the implementation of the Tax Acts 2025, providing a framework to manage Nigeria’s transition from repealed tax laws to a new tax regime scheduled to take effect on Jan. 1, 2026.
The guidelines, released by the Federal Ministry of Finance, are targeted at taxpayers, tax practitioners, revenue authorities and other stakeholders affected by the tax reforms.
They address issues arising from the transition, including the treatment of existing tax liabilities, ongoing audits, pending incentive applications and transactions that span both the old and new legal frameworks.
Speaking on the development, the Minister of Finance and Coordinating Minister of the Economy, Mr. Taiwo Oyedele, said the guidelines were designed to ensure a smooth transition while preventing the retroactive application of the new laws.
“The guidelines are anchored on three key principles – clarity, fairness and administrative certainty,” Oyedele said.
The Tax Acts 2025 consist of four major laws: the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act and the Joint Revenue Board (Establishment) Act.
According to the ministry, the Nigeria Tax Act, 2025, will come into force on Jan. 1, 2026.
Under the guidelines, all tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before Jan. 1, 2026, will continue to be administered under the repealed tax laws.
Similarly, tax returns for accounting periods ending before the commencement date will be filed under the old legal regime, while returns due from Jan. 1, 2026, onward will be governed by the new laws.
The guidelines also preserve existing tax incentives and exemptions granted under the repealed laws until their expiration dates, ensuring continuity for businesses and investors already benefiting from such arrangements.
However, new applications and pending requests for incentives will be considered under the provisions of the Tax Acts 2025.
The ministry said the document further clarifies the treatment of income taxes, transaction taxes, development levies, record-keeping obligations and transactions that cut across both legal regimes.
According to the ministry, the guidelines are intended to promote consistency in implementation across all revenue administration bodies, including the Nigeria Revenue Service, State Internal Revenue Services, the FCT Internal Revenue Service and Local Government Revenue Committees.
Oyedele described the Tax Acts 2025 as a major milestone in Nigeria’s tax reform agenda, noting that the guidelines provide certainty on how existing obligations, ongoing matters and future transactions will be handled during the transition period.
He said the framework would help taxpayers and administrators navigate the shift to the new regime while supporting improved tax administration and compliance nationwide.
