FG Issues Transition Guidelines For Tax Acts 2025

The federal government has issued the general guidelines for the implementation of the Tax Acts 2025, establishing a formal framework for managing the country’s transition from its repealed tax laws to a new tax regime that takes effect from January 1, 2026.

The guidelines, released by the Federal Ministry of Finance on Thursday, are addressed to taxpayers, tax practitioners, revenue authorities and other stakeholders, and cover a wide range of issues arising from the changeover — including the treatment of existing tax liabilities, ongoing audits, pending incentive applications, and transactions that straddle both the old and new legal regimes.

Speaking on the release, Finance Minister and Coordinating Minister of the Economy, Mr. Taiwo Oyedele, described the document as a framework for managing transitional issues while ensuring that the new laws are not applied with retroactive effect.

“The Guidelines are anchored on three key principles — clarity, fairness and administrative certainty,” Oyedele said.

The Tax Acts 2025 comprise four statutes: the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act. Each law carries its own commencement date as enacted. The Nigeria Tax Act, 2025, in particular, takes effect from January 1, 2026.

Under the guidelines, all tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before January 1, 2026, will continue to be handled under the repealed laws.

Tax returns covering accounting periods that ended before that date must also be filed under the previous legal framework, while returns due from January 1, 2026, onward will fall under the new regime.

Existing tax incentives and exemptions granted under the repealed laws will remain valid until they expire, providing continuity for businesses and investors that had secured such reliefs under the old framework.

However, new applications and pending requests will be reviewed under the provisions of the Tax Acts 2025.

The document also addresses the treatment of income taxes and transaction taxes, development levies, record-keeping obligations, and cross-regime transactions that begin under one legal order and conclude under the other.

The ministry said the guidelines are intended to ensure uniformity in implementation across all revenue administration bodies, including the Nigeria Revenue Service, State Internal Revenue Services, the FCT Internal Revenue Service, Local Government Revenue Committees, and the broader community of tax practitioners.

The minister described the Tax Acts 2025 as a significant milestone in Nigeria’s ongoing tax reform programme, saying the guidelines clarify how existing obligations, live matters and future transactions will be treated as the country moves from the old regime to the new framework.

1. The government reaffirmed its commitment to building what it described as a transparent, efficient and modern tax system that supports economic growth, strengthens revenue administration, encourages voluntary compliance and improves the country’s investment climate.