The Federal Government has issued the General Guidelines for the implementation of the Tax Acts 2025, providing a roadmap for the transition from the repealed tax laws to Nigeria’s new tax framework, which took effect on January 1, 2026.
The guidelines, released by the Federal Ministry of Finance, outline how taxpayers, tax practitioners, revenue authorities and other stakeholders should manage tax obligations during the transition from the old tax regime to the new system.
According to the Ministry, 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, with each taking effect from the commencement date stipulated in the respective laws. The Nigeria Tax Act specifically became effective on January 1, 2026.
The guidelines state that tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before the commencement date will continue to be handled under the repealed tax laws.
Similarly, tax returns for accounting periods ending before January 1, 2026, will be filed under the previous tax laws, while returns for accounting periods ending from January 1, 2026, onward will be administered under the new tax framework.
The document also provides guidance on the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping obligations and transactions spanning both the old and new tax regimes.
It further clarifies that existing tax incentives and exemptions granted under the repealed laws will remain valid until their expiration dates, while new applications and pending requests will be considered in line with the provisions of the Tax Acts 2025.
Speaking on the release of the guidelines, the Honourable Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, said the document establishes a clear framework for managing transitional issues without applying the new tax laws retrospectively.
“The Guidelines provide a framework for managing transitional issues while ensuring that the new laws are not applied retrospectively. They also set out how existing obligations, ongoing matters and future transactions will be treated under the new regime,” the Minister said.
Oyedele described the Tax Acts 2025 as a significant milestone in Nigeria’s tax reform programme, saying they provide a modern legal framework that simplifies tax administration, improves compliance and enhances certainty for taxpayers.
“The Tax Acts 2025 represent a significant milestone in Nigeria’s tax reform programme, providing a modern legal framework that simplifies tax administration, improves compliance and enhances certainty for taxpayers,” he said.
He added that the transition guidelines were developed to provide clarity for taxpayers and tax authorities as the country moves to the new tax regime.
“The transition guidelines have been developed to ensure that taxpayers, tax authorities and practitioners have a clear understanding of how existing obligations, ongoing matters and future transactions will be treated during the changeover to the new tax regime.”
According to the Minister, the Government’s objective is to ensure an orderly implementation process that safeguards taxpayers’ rights while promoting consistency in the application of the new laws.
“Our objective is to ensure a smooth and orderly transition that protects the rights of taxpayers, preserves legal certainty and promotes consistency in the application of the new tax laws.”
Oyedele noted that the guidelines are anchored on three key principles—clarity, fairness and administrative certainty—which he said would reduce uncertainty for businesses and investors.
“By providing clarity on transitional arrangements, we are reducing uncertainty for businesses and investors while strengthening confidence in Nigeria’s tax administration.”
He said the guidelines are intended to promote uniform implementation across the Nigeria Revenue Service, State Internal Revenue Services, the FCT Internal Revenue Service, Local Government Revenue Committees, tax practitioners and taxpayers nationwide.
“Uniform implementation across the Nigeria Revenue Service, State Internal Revenue Services, the FCT Internal Revenue Service, Local Government Revenue Committees and all stakeholders is critical to the success of these reforms.”
The Minister reaffirmed the Federal Government’s commitment to building a transparent, efficient and modern tax system that supports economic growth, strengthens revenue administration, encourages voluntary compliance and improves Nigeria’s investment climate.
“These Guidelines reinforce the Federal Government’s commitment to a transparent, efficient and predictable tax system that supports economic growth, encourages voluntary compliance and improves Nigeria’s investment climate,” he said.