FG Clarifies Transition from Old Tax Laws to New Tax Framework
The Federal Government has released the General Guidelines for the implementation of the Tax Acts 2025, providing a roadmap for the transition from repealed tax laws to Nigeria’s new tax framework, which takes effect from January 1, 2026.
The guidelines, issued by the Federal Ministry of Finance, are designed to assist taxpayers, tax practitioners, revenue authorities and other stakeholders in navigating issues arising during the transition from the old tax regime to the new one.
According to the document, 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. Each law will take effect on its respective commencement date as provided by legislation, with the Nigeria Tax Act scheduled to come into force on January 1, 2026.
The guidelines clarify that tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before the commencement date will continue to be governed by the repealed tax laws.
Similarly, tax returns for accounting periods ending before January 1, 2026, will be filed under the old laws, while returns due from that date onward will be administered under the new tax framework.
The document also outlines procedures for handling income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping requirements and transactions that extend across both tax regimes.
The government stated that existing tax incentives and exemptions granted under repealed laws will remain valid until their expiration dates. However, new applications and pending requests will be considered under 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, Mr. Taiwo Oyedele, said the document provides a clear framework for managing transitional issues while ensuring that the new laws are not applied retrospectively.
He described the Tax Acts 2025 as a major milestone in Nigeria’s tax reform agenda, adding that the guidelines clarify how existing obligations, ongoing matters and future transactions will be treated under the new system.
According to Oyedele, the guidelines are built on three core principles: clarity, fairness and administrative certainty.
The Ministry said the framework is intended to promote uniform implementation and support effective tax administration 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.
The Federal Government reaffirmed its commitment to developing a transparent, efficient and modern tax system capable of supporting economic growth, strengthening revenue administration, encouraging voluntary compliance and improving Nigeria’s investment climate.
